Facts:

The case involves Peregrina Astudillo (petitioner-appellant) against the Board of Directors of People's Homesite and Housing Corporation, Ramon P. Mitra, Salud O. Mitra, and the Register of Deeds of Quezon City (respondents-appellees). The events that transpired began on December 28, 1957, when Ramon P. Mitra applied for the purchase of Lot 16, Block E-155 of the East Avenue Subdivision in Pinahan, Quezon City, on behalf of his minor son, Ramon Mitra Ocampo. The application was approved on January 3, 1958, and a down payment of P840 was made, representing ten percent of the total price of the lot. A contract of conditional sale was executed on September 9, 1961, and after the full payment of over nine thousand pesos was made, a final deed of sale was issued on February 18, 1965. Consequently, Transfer Certificate of Title No. 89875 was issued on March 1, 1965, in favor of Mitra.

During this period, Peregrina Astudillo was in possession of the same lot since 1957, having cons

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Facts:

Background of the Transaction

• On December 28, 1957, Ramon P. Mitra applied on behalf of his minor son, Ramon Mitra Ocampo, for the purchase of Lot 16, Block E-155 of the East Avenue Subdivision managed by the People’s Homesite and Housing Corporation (PHHC) in Pinahan, Quezon City.
• The application was approved on January 3, 1958, with a downpayment of P840—equivalent to ten percent of the lot’s price.

Development of the Sale

• On September 9, 1961, a contract of conditional sale between PHHC and Mitra was executed.
• After full payment exceeding nine thousand pesos was rendered, a final deed of sale was executed on February 18, 1965.
• Transfer Certificate of Title No. 89875 was issued on March 1, 1965, thereby completing the sale in favor of Mitra.

Petitioner's Occupation and Actions

• Peregrina Astudillo, though not a party to the aforementioned sale, actually occupied Lot 16 and constructed a residential house (referred to by Mitra as a “shanty”).
• She admitted to squatting on the lot “uninterruptedly since 1957 up to the present.”
• On February 24, 1963, while the sale process was underway, she filed a request with the administrative investigating committee of PHHC, praying for the cancellation of the award to Mitra and recommending that the lot be re-awarded to her. No action was taken on this request.

Filing of the Petition and Subsequent Proceedings

• On May 3, 1965, Peregrina Astudillo filed her petition in the Rizal, Quezon City Branch V of the Court of First Instance, questioning the legality of the award of Lot 16 to Mitra and asking that the lot be sold to her instead.
• Although the respondents (Mitra, his spouse Salud O. Mitra, and the register of deeds of Quezon City) filed answers, the Mitra spouses moved for summary judgment on the ground that there was no genuine issue as to any material fact.
• The lower court treated the summary judgment motion as a motion to dismiss, ruling against Peregrina on the basis that she was a mala fide squatter and that the sale to Mitra could not be assailed via the remedies of certiorari and mandamus.

Assignments of Error Raised on Appeal

• Peregrina contended that the lower court erred in dismissing her petition by asserting that certiorari and mandamus were not available to review the award.
• She argued that the award of Lot 16 to Mitra violated provisions of the Anti-Graft and Corrupt Practices Law as well as constitutional provisions barring certain government officials from being directly or indirectly financially interested in government contracts.
• The fundamental issue, however, centered on whether she had a valid cause of action to annul the sale and compel PHHC to re-award the lot to her.

Issue:

Cause of Action

• Whether Peregrina Astudillo, as a squatter, has a legal cause of action to annul the award of Lot 16 to Mitra and to obtain the lot for herself.

Availability of Special Civil Actions

• Whether the remedies of certiorari and mandamus are applicable tools for challenging the award of the lot, given the nature of the proceedings and the actions of the PHHC board.

Alleged Violations of Law

• Whether the award of Lot 16 to Mitra violated section 3(h) of the Anti-Graft and Corrupt Practices Law.
• Whether the award contravened provisions (section 17, Article VI of the 1935 Constitution, now section 11, Article VIII of the new Constitution) that restrict certain government officials from engaging in contracts with government entities during their terms of office.

Rights and Possessory Interests

• Whether Peregrina’s long-term occupation of Lot 16 confers upon her any possessory rights that might justify her claim despite the legal sale to Mitra.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)