Title
Campos vs. Ortega Sr.
Case
G.R. No. 171286
Decision Date
Jun 2, 2014
Petitioner, a ZIP beneficiary, failed to prove vested rights or fraud in NHA’s property award to respondents; SC upheld Torrens title’s indefeasibility, denying her claim.
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Case Digest (G.R. No. 171286)

Facts:

  1. Occupancy and Lease Agreement

    • Petitioner Dolores Campos, along with her husband Ernesto Campos and their family, occupied the second level and front portion of the ground level of a residential structure located at No. 208 F. Blumentritt Street, Mandaluyong City. The lot was government-owned, while the structure was owned by Dominga Boloy, from whom the Campos family leased the property starting in 1966.
    • Petitioner paid real estate taxes on behalf of Dominga Boloy in 1987, including arrearages from 1979, due to Boloy's apparent abandonment of these obligations.
  2. Zonal Improvement Program (ZIP)

    • In 1977, under the ZIP of the Metro Manila Commission, a census of the Hulo estate was conducted. Petitioner was censused and qualified as a bona fide occupant, receiving an identifying house tag number (77-00070-08) on August 20, 1977.
  3. Improvements and Agreements

    • After Dominga Boloy's death in 1979, petitioner had a verbal agreement with Clarita Boloy (Dominga’s daughter-in-law) to introduce improvements to the structure, with the understanding that the expenses (P10,000.00) would be applied to monthly rentals. However, this agreement was not honored, and petitioner continued paying rent.
  4. Ejectment Suit

    • In 1987, Walter Boloy demanded petitioner vacate the premises and filed an ejectment suit, which was dismissed by the Metropolitan Trial Court on February 12, 1986.
  5. Follow-Up with NHA

    • Petitioner, through her attorney-in-fact Salvador Pagunsan, followed up with the National Housing Authority (NHA) regarding the award of the lot under the ZIP. She was informed that if Ernesto Campos could buy the property from Walter Boloy, he could be awarded the lot.
  6. Meetings and Offers

    • On November 19, 1987, petitioner was given until December 19, 1987, to purchase Lot 17, Block 7, Phase III of the Hulo estate. However, petitioner refused because she occupied Lot 18, not Lot 17.
    • Subsequent meetings were scheduled, but no NHA representatives attended. Meanwhile, on November 23, 1987, a Deed of Absolute Sale was executed between Clarita Boloy and respondent Dominador Ortega, Sr., transferring Lot 17 to Ortega.
  7. Award to Respondents

    • On February 4, 1988, the property was awarded to respondents Dominador Ortega, Sr. and James Silos. A second Deed of Absolute Sale was executed on February 19, 1988, omitting petitioner’s name as a renter and home-lot applicant.
  8. Legal Action

    • Petitioner filed a complaint for specific performance and damages on August 17, 1999, alleging that respondents were disqualified beneficiaries under the ZIP guidelines and that the award was irregular.

Issue:

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Ruling:

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Ratio:

  1. Vested Rights

    • A vested right must be absolute, complete, and unconditional. The issuance of a house tag number under the ZIP program did not confer such a right. It was merely a recognition of petitioner’s status as a qualified beneficiary, not a guarantee of lot allocation.
  2. Presumption of Regularity

    • Official acts, including the NHA’s award of the property to respondents, are presumed regular unless proven otherwise. Petitioner failed to present clear and convincing evidence of fraud or irregularities.
  3. Indefeasibility of Torrens Title

    • A Torrens title is indefeasible and cannot be collaterally attacked. Any challenge to the validity of the title must be made through a direct proceeding, such as an action for reconveyance.
  4. Proper Remedy

    • Petitioner’s failure to file an action for reconveyance within the prescriptive period (four years for fraud, ten years for constructive trust) barred her from seeking relief. Since she was no longer in possession of the property, her claim was also time-barred.

Conclusion:

The Supreme Court affirmed the Court of Appeals' decision, ruling that petitioner Dolores Campos had no vested right over the property and failed to prove fraud or irregularities in the NHA’s award to respondents. The Court emphasized the indefeasibility of Torrens titles and the need for proper legal remedies, such as an action for reconveyance, to challenge title validity.


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