Case Digest (G.R. No. 162784)
Facts:
National Housing Authority v. Segunda Almeida, Court of Appeals, and RTC of San Pedro, Laguna, Br. 31, G.R. No. 162784, June 22, 2007, Supreme Court First Division, Puno, C.J., writing for the Court.The dispute concerns several lots in the Tunasan Estate, San Pedro, Laguna originally awarded on June 28, 1959 by the Land Tenure Administration (LTA) to Margarita Herrera under Agreement to Sell No. 3787. The LTA later devolved into the Department of Agrarian Reform and ultimately, by Presidential Decree No. 757 (July 31, 1975), the National Housing Authority (NHA) became the successor agency; NHA is the petitioner here. Margarita had two children, Beatriz Herrera-Mercado (predeceased Margarita and is the progenitor of private respondent Segunda Mercado-Almeida) and Francisca Herrera.
On October 7, 1960 Margarita executed a notarized Sinumpaang Salaysay in which she declared that upon her death a specified lot was to be given to her daughter Francisca; the instrument bore Margarita’s thumbmark. In 1974 Francisca executed a Deed of Self-Adjudication claiming to be sole heir. The surviving heirs of Beatriz challenged that Deed in Civil Case No. B-1263 before the then Court of First Instance of Laguna; on December 29, 1980 the Deed of Self-Adjudication was declared null and void.
Despite the preceding litigation, Francisca applied to the NHA to purchase the subject lots (submitting the Sinumpaang Salaysay). Segunda Almeida protested. In a Resolution dated February 5, 1986 the NHA granted Francisca’s application, finding she had the better preferential right; the Office of the President affirmed that NHA resolution on January 23, 1987. Francisca died on February 1, 1987; her heirs executed an extrajudicial settlement and the NHA later executed deeds of sale and caused titles (TCTs) to be issued in favor of certain heirs (Macario, Alberto, Antonio). Almeida was directed to vacate.
Almeida filed a complaint for "Nullification of Government Lot's Award" with the Regional Trial Court (RTC) of San Pedro, Laguna (Civil Case No. B-2780) on February 8, 1988, asserting long occupation and that Francisca’s Deed of Self-Adjudication had been voided. The RTC initially dismissed for lack of jurisdiction (Order dated June 14, 1988). The Court of Appeals (CA) reversed on June 26, 1989, holding the RTC had jurisdiction over title and possession and remanded the case for trial. After trial the RTC rendered judgment on March 9, 1998 setting aside the NHA resolution and the Office of the President decision, declaring the deeds of sale and titles void and ordering cancellation of titles; attorney’s fees were awarded to Almeida. Motions for reconsideration were denied (July 21, 1998). The heirs’ brief on appeal was denied admission by the CA (Resolution Jun...(Pro-only)
Issues:
- Does the resolution of the NHA and the decision of the Office of the President enjoy finality such that the doctrine of administrative res judicata bars the courts from determining preferential award rights over the subject lots?
- Did the Regional Trial Court have jurisdiction to hear and decide Almeida’s action involving title and possession of the subject lots?
- Was the NHA’s a...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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