G.R. No. 135402-03 - People vs. Gonzaga

The lot in dispute is situated in Diliman, Quezon City, with an area of 588 square meters.
Originally owned by the Peoples Homesite and Housing Corporation (PHHC), now transformed into the National Housing Authority.

In 1957, Benjamin Labayen applied for the purchase of the lot.
His application was opposed by Cenon Martires, Faustino Morales, and Iluminada Amansec, each asserting adverse claims over the property.
A special committee was formed to examine the protests, and after hearing all parties, it recommended in favor of Labayen on December 12, 1961.
On December 15, 1961, the PHHC approved Labayen’s application and confirmed the award of the lot to him.
Of the opposers, only Morales appealed the PHHC’s action to the Office of the President, while Martires and Amansec did not take any administrative appeal.
After nearly eight years, on February 19, 1969, the appeal by Morales was dismissed, thereby affirming the award in favor of Labayen.

Labayen paid the full purchase price for the lot, which resulted in a deed of sale dated February 28, 1969.
The land was subsequently registered in his name under Transfer Certificate of Title (TCT) No. 137894 with the Register of Deeds of Quezon City.

On April 20, 1972, Labayen initiated a complaint for recovery of possession (Civil Case No. Q-16475) asserting his title and the wrongful occupation by the opposers who had constructed dwellings on the lot.
Respondents’ defenses varied:

Martires claimed that Labayen’s title was void from the outset as it was fraudulently obtained, and that he was a bona fide possessor since he had occupied the land since 1954.
Anna Morales (substituting her deceased husband) asserted similar defenses and even initiated a separate complaint (Civil Case No. Q-20337) seeking nullification of Labayen’s title on grounds of fraud and disqualification.
Martires subsequently filed a complaint in intervention challenging both parties’ titles, insisting on a superior right to the lot.

On October 22, 1982, Judge Jose P. Castro of the Court of First Instance of Rizal rendered a decision:

In Civil Case No. Q-16475, he ordered the opposers to vacate the property and imposed monetary penalties on them.
In Civil Case No. Q-20337, the claims of Anna Morales and the intervention by Martires were dismissed.

The Court of Appeals affirmed the trial court’s decision in its entirety.
A subsequent motion for reconsideration led to a temporary modification by awarding the lot to Anna Morales; however, this resolution was later nullified on April 6, 1987, reinstating the original decision dismissing the appeal.

Cenon Martires subsequently filed a petition for certiorari under Rule 45, arguing grave abuse of discretion by the lower courts in upholding Labayen’s award.
Martires contended that he was entitled to the lot and challenged the administrative process on the ground that he was a bona fide possessor, though factual evidence did not support such a claim.
The petition was raised only after a significant lapse of time – more than a decade after the administrative decision – following a 1972 lawsuit for recovery of possession.

Whether the administrative process and the committee’s recommendation awarding the lot to Labayen were correct and free from grave abuse of discretion.
Whether Martires, as petitioner, could validly challenge the administrative decisions despite not exhausting all available administrative remedies when opposing Labayen’s application in 1961.
Whether the petition for certiorari under Rule 45 is proper, given the issue raised is predominantly factual and not merely a question of law.
Whether Martires’ claim as a bona fide possessor of the lot holds merit considering he neither secured permission for occupation nor participated in the administrative appeal process.
Whether the doctrine of laches should apply due to the extensive delay in seeking judicial redress.