Solid Homes, Inc. vs.

Payawal, 177 SCRA 72, 79 (1989)

FACTS:
Payawal is a buyer of a certain subdivision lot who is suing Solid Homes for failure to
deliver the certificate of title. The complaint was filed with the RTC. Solid Homes
contended that jurisdiction is with the National Housing Authority (NHA) pursuant to PD
957, as amended by PD 1344 granting exclusive jurisdiction to NHA.
ISSUE:
W/N NHA has jurisdiction to try the case and the competence to award damages
HELD:
In case of conflict between a general law and a special law, the latter must prevail
regardless of the dates of their enactment. It is obvious that the general law in this case
is BP 129 and PD 1344 the special law. Thus, NHA (now HLURB) has jurisdiction in this
case
to
try
the
case,
as
well
as,
to
award
for
damages.
Statutes conferring powers on their administrative agencies must be liberally construed
to enable them to discharge their assigned duties in accordance with the legislative
purpose.
Ernesto M. Maceda vs. Energy Regulatory Board, et al.
18 July 1991
::
G.R. No. 96266
Medialdea, J.
FACTS:
Upon the outbreak of the Persian Gulf conflict on August 1990, private respondents, the
oil companies, filed with the ERB their respective applications on oil price increases.
ERB then issued an order granting a provisional increase. However, Petitioner Maceda
filed a petition for Prohibition seeking to nullify said increase.
ISSUE:
Whether or not the decisions of the Energy Regulatory Board should be subject to
presidential review.
HELD:

Pursuant to Section 8 of E.O. No. 172, while hearing is indispensable, it does not
preclude the Board from ordering a provisional increase subject to final disposition of
whether or not to make it permanent or to reduce or increase it further or to deny the
application. The provisional increase is akin to a temporary restraining order, which are
given ex-parte.
The Court further noted the Solicitor Generals comments that the ERB is not averse to
the idea of a presidential review of its decision, except that there is no law at present
authorizing the same. The Court suggested that it will be under the scope of the
legislative to allow the presidential review of the decisions of the ERB since, despite its
being a quasi-judicial body, it is still an administrative body under the Office of the
President whose decisions should be appealed to the President under the established
principle of exhaustion of administrative remedies, especially on a matter as
transcendental as oil price increases which affect the lives of almost all Filipinos.