Case Digest (G.R. No. L-25874)
Facts:
- Manuel C. Castaneda, Chairman of the Land Tenure Administration, and the Court of Appeals are respondents against petitioner Juanita Vizcarra.
- In 1947, the Baclaran Estate in Parañaque, Rizal, was acquired and subdivided into home lots by the government under Commonwealth Act No. 539.
- Mariano Vizcarra, a tenant, occupied Lot 21-B, measuring approximately 773 square meters.
- Lot 21-B was later subdivided into Lot 13-A (Block 62), measuring 148 square meters, applied for in the name of Mariano's daughter, Juanita Vizcarra.
- On April 23, 1948, the Rural Progress Administration (RPA) executed an agreement to sell Lot 13-A to Juanita, which was fully paid by May 3, 1948.
- The RPA failed to execute a final deed of sale as required by the agreement.
- On July 6, 1954, Simplicio Almando claimed to be the actual occupant of Lot 13-A, protesting the sale to Juanita.
- The case was transferred to the Land Tenure Administration (LTA) and docketed as LTA Case No. 124.
- The LTA ruled that Juanita had never occupied Lot 13-A and granted Almando the preferential right to purchase it.
- This decision was upheld by the Office of the President.
- Juanita and her husband filed an action in the Court of First Instance of Rizal to annul the LTA's decision, but the court ruled in favor of Almando.
- Juanita appealed, and the Court of Appeals declared her entitled to priority in purchasing Lot 13-A, reversing the lower court's ruling.
- Almando sought a review from the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court reversed the decision of the Court of Appeals.
- The ruling of the Court of First Instance was affirmed, declaring Simplicio Almando entitled to priority in the pu...(Unlock)
Ratio:
- The Supreme Court based its ruling on the established fact that Almando was the actual occupant of Lot 13-A, supported by evidence from administrative proceedings.
- The Court emphasized that findings of fact by executive authorities are binding on courts unless evidence of fraud, imposition, or mistake is present, which was not t...continue reading
Case Digest (G.R. No. L-25874)
Facts:
The case involves Manuel C. Castaneda, as Chairman of the Land Tenure Administration, and the Court of Appeals as respondents against Juanita Vizcarra, the petitioner. The events leading to this case began in 1947 when the Baclaran Estate in Parañaque, Rizal, was acquired and subdivided into home lots by the government under Commonwealth Act No. 539. Among the tenants was Mariano Vizcarra, who occupied Lot 21-B, which measured approximately 773 square meters. This lot was later subdivided, resulting in Lot 13-A (Block 62), with an area of 148 square meters, which was applied for in the name of Mariano's daughter, Juanita Vizcarra. On April 23, 1948, the Rural Progress Administration (RPA) executed an agreement to sell the lot to Juanita, and by May 3, 1948, the lot was fully paid for. However, the RPA failed to execute a final deed of sale as stipulated in the agreement.
On July 6, 1954, Simplicio Almando, who later passed away and was substituted by his heirs, wrote to the Bureau of Lands claiming that he was the actual occupant of Lot 13-A and protested the sale to Juanita. An investigation was conducted, and the case was transferred to the newly created Land Tenure Administration (LTA), where it was docketed as LTA Case No. 124. The LTA Chairman, Manuel E. Castaneda, ruled that Juanita had never occupied Lot 13-A and that Almando was the actual occupant, thus granting Almando the preferential right to purchase the lot. This decision was upheld upon appeal to the Office of the President.
Juanita, with her husband, subsequently filed an actio...