Case Digest (G.R. No. 164244)
Facts:
The case involves a dispute between the National Housing Authority (NHA) as the petitioner and Reynaldo Magat as the respondent, with the relevant legal proceedings taking place in the Philippines. The dispute arose from a parcel of land known as Lot 53, Block 1, within the PeAafrancia ZIP Project, which became the subject of conflicting claims between Armando De Guzman and Reynaldo Magat. On June 26, 1998, the NHA issued a Memorandum resolving this conflict and awarding the lot solely to De Guzman. Magat, who contested this decision, filed an appeal with the Office of the President, which upheld the NHA’s award in a Resolution dated November 26, 2002. Magat subsequently sought reconsideration, which was denied in an Order dated May 29, 2003. Dissatisfied with this outcome, Magat escalated the matter to the Court of Appeals, which considered various factors including Magat's standing as a censused renter in the ZIP Project and the existence of two distinct structures on the
Case Digest (G.R. No. 164244)
Facts:
Background of the Case
The case involves a dispute over Lot 53, Block 1, Peñafrancia ZIP Project in Paco, Manila. The National Housing Authority (NHA) issued a Memorandum on 26 June 1998, resolving the conflicting claims between Armando De Guzman (De Guzman) and Reynaldo Magat (Magat). The NHA recommended that the lot be awarded solely to De Guzman.
Magat's Appeal to the Office of the President
Magat appealed the NHA's decision to the Office of the President, which upheld the NHA's Memorandum in a Resolution dated 26 November 2002. Magat's motion for reconsideration was denied on 29 May 2003.
Magat's Appeal to the Court of Appeals
Magat then filed an appeal with the Court of Appeals, which set aside the Resolutions of the Office of the President and the NHA Memorandum. The Court of Appeals found that:
- Magat was a censused renter in the Peñafrancia ZIP Project.
- Magat was occupying a structure on Lot 53 under a lease contract with Clarita Punzalan, as evidenced by rental receipts.
- The structure purchased by De Guzman was separate from the one leased by Magat.
- There were two structures on Lot 53, and Magat, as a censused renter, had the right to own the portion he was occupying.
The Court of Appeals ruled that the NHA committed a grave abuse of discretion by not recognizing Magat's rights and awarded Magat the right to purchase the portion of the lot he was occupying.
De Guzman's Petition to the Supreme Court
De Guzman filed a petition for review with the Supreme Court (G.R. No. 164162), which was denied on 22 November 2004. The denial became final and executory on 14 January 2005.
NHA's Petition to the Supreme Court
The NHA filed the present petition for review (G.R. No. 164244) challenging the Court of Appeals' decision. However, the Supreme Court noted that the issue had already been resolved in G.R. No. 164162, rendering the present petition moot.
Issue:
- Whether the NHA is a real party in interest in the case.
- Whether the Court of Appeals committed reversible error in its decision.
- Whether the Supreme Court should entertain the NHA's petition, given the finality of the resolution in G.R. No. 164162.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Conclusion:
The Supreme Court denied the NHA's petition, affirming the Court of Appeals' decision and emphasizing that the NHA is not a real party in interest. The case is moot due to the finality of the resolution in G.R. No. 164162.