Case Digest (G.R. No. L-28066)
Facts:
Peregrina Astudillo v. The Board of Directors of People's Homesite and Housing Corporation, Ramon P. Mitra, Salud O. Mitra, and Register of Deeds, Quezon City, G.R. No. L-28066, September 22, 1976, Supreme Court Second Division, Aquino, J., writing for the Court.
Petitioner Peregrina Astudillo occupied Lot 16, Block E-155 of the East Avenue Subdivision (Pinahan, Quezon City) “uninterruptedly since 1957” and constructed a dwelling thereon. On December 28, 1957 respondent Ramon P. Mitra applied, on behalf of his minor son Ramon Mitra Ocampo, to purchase the same lot from respondent People’s Homesite and Housing Corporation (PHHC). The PHHC approved the application on January 3, 1958. Mitra made a downpayment of P840 (ten percent of the price), executed a contract of conditional sale on September 9, 1961, paid the balance in full, had a final deed of sale executed in his favor on February 18, 1965, and a Transfer Certificate of Title No. 89875 was issued to him on March 1, 1965.
Astudillo filed an administrative request with a PHHC investigating committee on February 24, 1963, seeking cancellation of the award to Mitra and re‑award of the lot to her; no action followed. On May 3, 1965 she filed a petition in the Court of First Instance of Rizal, Quezon City Branch V (Civil Case No. Q‑8741) against the PHHC Board of Directors, the Register of Deeds of Quezon City and the Mitra spouses, questioning the legality of the award to Mitra and asking that Lot 16 be sold to her.
Respondents filed answers and the Mitras moved for summary judgment, asserting no genuine issue of material fact. Astudillo opposed; parties submitted memoranda. The trial court treated the motion for summary judgment as a motion to dismiss and, by resolution dated April 18, 1967, granted the...(Pro-only)
Issues:
- Are the special civil actions of certiorari and mandamus appropriate remedies to challenge the PHHC board’s award of Lot 16 to Mitra?
- Does petitioner, as a squatter in possession of Lot 16, have a cause of action to annul the sale to Mitra and to compel the PHHC to re‑award the lot to her?
- May petitioner, in this action, successfully invoke section 3(h) of the Anti‑Graft and Corrupt Practices Law and section 17, Article VI of the 1935 Constitution...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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