G.R. No. L-8036; L-8037 - Marukot vs. Jacinto

The Tambobong Estate, located in Malabon, Rizal, comprises several lots, including lot No. 35, block No. 12.
The lots subject of the dispute are:

Gabriel Marukot has possessed lot 35-B since 1940, residing in a house built on the lot with his family.
Felipe Baisa has possessed lot 35-D since 1946, with his family residing in his house thereon.
Lorenzo Baltazar has possessed lot 35-E since 1944, with his family residing in the house on the lot.

The Government purchased the Tambobong Estate from the Roman Catholic Church on December 31, 1947.
Commonwealth Act No. 539 empowers the President to acquire private lands for resale as home lots or small farms under reasonable conditions, particularly favoring bona fide tenants or occupants.

Amado Jacinto, the lessee of lot No. 35 (inclusive of lots 35-B, 35-D, and 35-E), filed an application with the Rural Progress Administration to purchase the entire lot.
The basis of Jacinto’s application was that he, and his predecessors in interest, had possessed the lot as a lessee who paid rentals to the former owners.
Gabriel Marukot, Felipe Baisa, and Lorenzo Baltazar opposed the application regarding the portions of the lot they actually occupied.

The Bureau of Lands, which assumed the functions of the Rural Progress Administration, rendered a decision on December 22, 1951, dismissing the oppositions and adjudicating the entire lot to Amado Jacinto.
Separate cases were instituted in the Court of First Instance of Rizal by:

Gabriel Marukot against Jacinto and the Director of Lands (Civil Case No. 1690).
Lorenzo Baltazar against the same defendants (Civil Case No. 1696).
Felipe Baisa against the defendants (Civil Case No. 1705).

The trial court issued judgments declaring the December 22, 1951, adjudication null and void, and declared the respective plaintiffs entitled to purchase the specific lots they occupied, issuing orders for the Director of Lands to approve these purchase applications.

Amado Jacinto and the Director of Lands appealed the trial court decisions to the Court of Appeals, arguing that the appellate decision contradicted the facts and the law.
The Court of Appeals, certifying the case to the Supreme Court, recognized that the controversy boiled down to a legal question regarding the proper preference between:

Plaintiffs-appellees (the bona fide occupants and sublessees).
Defendant-appellant Amado Jacinto (the original lessee who was not in actual possession).

The factual situation established that although Jacinto was the lessee with prior rentals paid, the plaintiffs had been in actual possession of their respective lots since 1940, 1944, and 1946, with established residences and continuous rental payments as sublessees.

Whether the bona fide occupants (the plaintiffs-appellees) have preference over the original lessee, Amado Jacinto, in acquiring the lots they occupy.
How the legal rights of a sublessee who is in actual possession compare with those of a tenant who is not in possession.

Whether the provisions of Commonwealth Act No. 539 favor bona fide occupants over tenants in the context of acquisition and purchase by individuals.
Whether the legislative intent of providing affordable home lots to bona fide tenants or occupants has been maintained in the adjudication.

Whether the decision of the Bureau of Lands should be considered final or subject to judicial scrutiny without a prior administrative appeal.
Whether proper procedure was followed given that the case did not fall within the purview of the Public Land Act but under the Rural Progress Administration and subsequently the Bureau of Lands.