G.R. No. L-24421 - GONGON vs. COURT OF APPEALS

The property in controversy is Lot 18-B, Block 23 of the Tambobong Estate in Malabon, Rizal, originally part of a larger estate owned by the Roman Catholic Church.
Amada Aquino, the registered lessee of the lot, originally leased the property and later sublet it in 1934 to Matias Gongon for a 15‑year term at a nominal monthly rental of P6.00.
Gongon constructed his residential house on the lot and resided there with his family.

The Government acquired the entire Tambobong Estate from the Roman Catholic Church on December 31, 1947, under Commonwealth Act No. 539.
This Act empowered the President to acquire private lands and to subdivide them for resale to bona fide occupants or tenants—indicating a policy favoring the landless.

Matias Gongon, asserting his status as bona fide occupant as a sublessee, filed an application with the now-defunct Rural Progress Administration for the purchase of Lot 18-B, Block 23.
Amada Aquino opposed Gongon’s application by filing her own, invoking her preferential right as bona fide tenant.
The Director of Lands initially approved Gongon’s application on May 31, 1955, recognizing his actual occupancy of the lot.
On appeal, however, the Secretary of Agriculture and Natural Resources set aside the Director’s decision, giving due course to Aquino’s application.
Gongon’s subsequent motion for reconsideration was denied by the Land Tenure Administration (LTA), which had assumed the functions and powers of the Bureau of Lands pursuant to Republic Act No. 1400.
Ultimately, on February 24, 1961, the LTA executed a deed of sale in favor of Amada Aquino, and she obtained Transfer Certificate of Title No. 84738 on March 10, 1961.

On April 24, 1961, Matias Gongon filed a complaint in the Court of First Instance of Manila seeking:

An annulment of the decisions of the LTA and the Office of the President.
An award of the lot to himself and cancellation of the registration in Aquino’s name.
A prayer for attorney’s fees and other costs.

The lower court dismissed Gongon’s complaint.
The decision was subsequently affirmed by the Court of Appeals, which held that:

The finding that Gongon had waived any right over the lot, as determined by the Secretary of Agriculture and Natural Resources and affirmed by the Office of the President, was a factual issue beyond judicial review.
As a sublessee, Gongon’s possession was essentially that of the bona fide tenant (Amada Aquino) and thus did not grant him the status of an actual occupant under the law.

Gongon contended that his status as a sublessee (occupant) entitled him to a preferential right to purchase the lot over Aquino, the registered tenant.
He argued that any waiver of his right was invalid because it ran contrary to public policy, as enshrined both in Commonwealth Acts and in provisions of the Civil Code regarding the waiver of rights.

Whether petitioner Matias Gongon, as a sublessee and bona fide occupant, is entitled to the preferential right to purchase Lot 18-B, Block 23 over the bona fide tenant petitioner Amada Aquino.
If such a preferential right exists, whether the alleged waiver of that right by Matias Gongon is valid and enforceable, given that it may contravene public policy.