G.R. No. 116151 - Almora vs. Court of Appeals

Petitioners Ester Jane Virginia F. Almora and Albert F. Almora filed a complaint on February 13, 1985, against private respondents Orlando Peralta and Rudy Peralta in the Regional Trial Court (RTC) of Baguio City. They sought to recover possession of a parcel of land in Abatan, Buguias, Benguet, with an area of about 830 square meters, which was occupied by the Peraltas.

The disputed property is part of the Mount Data National Reservation Park, a public land. Ben Almora, the late father of the petitioners, was granted an occupancy permit by the Bureau of Forestry. The Almoras consistently paid real property taxes on the land from 1945 until 1987.

The land covered by the occupancy permit was divided into two lots: Lot A (one hectare) and Lot B (four hectares). On May 30, 1958, Ben Almora leased the disputed property to Federico Peralta, the father of the private respondents, under a Contract of Lease. The lease stipulated that if Federico Peralta paid the monthly rentals for three years, he would become the owner of the building on the land, but not the land itself.

Federico Peralta failed to pay the rentals, leading Ben Almora to file an unlawful detainer case against him. The Municipal Trial Court (MTC) ruled in favor of Almora, ordering Peralta to vacate the premises and pay the arrears. This decision was affirmed by the Court of First Instance (CFI) on December 29, 1972, and became final and executory.

Despite the court order, the Peraltas refused to vacate the property. After Federico Peralta's death, his children (private respondents) built houses on the land and continued to occupy it. Ben Almora sold the land to his children (petitioners) through a Deed of Sale of Unregistered Lands dated August 1, 1981.

Private respondents argued that their father ceased paying rent upon learning that Ben Almora did not own the land but merely held an occupancy permit. They also pointed out that the permit prohibited alienation or subletting of the property. Federico Peralta filed a Miscellaneous Sales Application with the Bureau of Lands in 1959, and other lessees followed suit.

The conflicting claims reached the Secretary of Agriculture and Natural Resources (SANR) and the Office of the President. In Decision No. 1039 dated July 18, 1974, the Office of the President ruled in favor of Federico Peralta and the other lessees, allowing them to continue occupying the land upon issuance of occupancy permits by the Bureau of Forest Development.

On April 30, 1990, the RTC ruled in favor of the petitioners, ordering the Peraltas to vacate the property and restore possession to the Almoras. The RTC based its decision on the Almoras' prior possession of the land, which predated the Peraltas' occupation by 13 years.

The Court of Appeals reversed the RTC decision, dismissing the complaint. The CA held that Ben Almora's occupancy permit did not confer ownership rights and that the lease contract was void. It also ruled that the issue of prior possession had already been resolved in the unlawful detainer case, which was not enforced within the prescribed period.

Prior Possession vs. Legal Right: While the petitioners had prior possession of the land, this did not confer ownership or a superior right to possess the land. The occupancy permit issued to Federico Peralta by the Bureau of Forestry gave him and his successors-in-interest a legal right to possess the land, which superseded the petitioners' claim of prior possession.
Validity of the Lease Contract: The lease contract between Ben Almora and Federico Peralta was void because Ben Almora did not own the land and could not lease it. The occupancy permit he held specifically prohibited alienation or subletting of the property.
Administrative Decision: The Office of the President's decision allowing both parties to continue occupying the land under permits was final and executory. This decision resolved the issue of possession and precluded the petitioners from recovering the land through an accion publiciana.
Forum-Shopping: The petitioners were found to have engaged in forum-shopping by filing multiple actions to recover possession of the land. This practice is prohibited as it undermines the judicial process and leads to conflicting decisions.
Failure to File Appellee's Brief: The petitioners' failure to file an appellee's brief in the Court of Appeals was a significant procedural lapse. This failure gave rise to a presumption that the appellants' arguments were valid, further weakening the petitioners' case.

The Supreme Court upheld the decision of the Court of Appeals, ruling that the private respondents had a better right to possess the disputed land based on the occupancy permit issued to Federico Peralta. The petitioners' claim of prior possession was insufficient to overcome the legal rights conferred by the permit. The Court also emphasized the importance of adhering to procedural rules and avoiding forum-shopping.