General Law vs. Special Law: Which should prevail in case of conflict?

   TOPICS:

1. Which should prevail in case of conflict between a special law and a general law? 
2. What should be the rule in construction in case of doubt in statutes conferring powers to administrative bodies?

Solid Homes, Inc. vs. Payawal

FACTS:

Petitioner Payawal entered into a contract to sell with Respondent Solid Homes, Inc. in 1975 over a subdivision lot in Marikina. Despite being fully paid in 1981, Respondent failed to execute a Deed of Sale in favor of the Petitioner. 

Hence, the Petitioner filed a complaint before the RTC Quezon City requesting the Respondent for the delivery of the title or, alternatively, the return of all the amounts they paid. The Respondent, in turn, moved to dismiss the complaint on the ground that the court had no jurisdiction, it being vested in the National Housing Authority under PD 957, as amended by PD 1344.

The RTC ruled in favor of the Petitioner and cited BP 129 as the basis of its jurisdiction. BP 129 is a later enactment, promulgated in 1981, as opposed to PD 957 as amended by PD 1344, as promulgated in 1978. 

ISSUE:

Whether or not the RTC has jurisdiction over the complaint involving refund or any other claims by a subdivision lot buyer against the developer. 

RULING: 

No, the RTC has no jurisdiction over the complaint involving a refund or any other claims by a subdivision lot buyer against the developer.

Under the rules of statutory construction, in case of conflict between a general law and a special law, the latter must prevail. Where the general act is later, the special statute will be construed as remaining an exception to its terms, unless repealed expressly or by necessary implication.

In this case, PD 957 as amended by PD 1344, a special law, should prevail over B.P. 129, a general law.  Although BP 129 is a later general law governing the general jurisdiction of the Regional Trial Court, it did not repeal PD 957 as amended by PD 1344, an earlier special law granting the National Housing Authority jurisdiction over refunds or any other claims by a subdivision lot buyer against the developer. Thus, the jurisdiction of the NHA should be construed as an exception to the general jurisdiction of the RTC.

Therefore, it is the NHA, and not the RTC, that has jurisdiction over refunds or any other claims by a subdivision lot buyer against the developer.