- Petitioner
- San Miguel Properties
- Respondent
- Bf Homes
- Citation
- G.R. No. 169343
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Leonardo-De Castro, J.
- Decided
- August 5, 2015
Summary
SMPI purchased 130 subdivision lots from BF Homes through rehabilitation receiver for P106,247,701.00 and paid in full by 1995. BF Homes delivered 110 TCTs but refused to deliver the remaining 20, claiming unauthorized sale and inadequate price. SMPI filed specific performance complaint with HLURB, which suspended proceedings pending SEC resolution of receiver's authority. The Supreme Court ultimately ruled for SMPI, holding that: (1) HLURB had exclusive jurisdiction and should have decided without suspension; (2) the sale contracts were valid despite being unnotarized private documents, having been ratified by BF Homes' acceptance of payment; (3) the rehabilitation receiver's acts were presumptively regular; (4) inadequate consideration alone cannot void a contract absent fraud; and (5) BF Homes was estopped from refusing delivery after accepting benefits. The Court ordered delivery of the 20 TCTs and awarded P100,000 attorney's fees, emphasizing the public interest in prompt resolution of subdivision buyer protection cases under the specialized statutory framework of Presidential Decree No. 957.