Title
National Housing Authority vs. Pascual
Case
G.R. No. 158364
Decision Date
Nov 28, 2007
NHA awarded Tatalon Estate lot to absentee Maranan; Pascual contested. SC ruled Maranan disqualified, voided title, ordered NHA to award lot to Pascual, a qualified beneficiary.

Case Digest (G.R. No. L-46001)

Facts:

  • Legislative and Administrative Background
    • Republic Act (R.A.) No. 2616 (enacted August 3, 1959) provided for the expropriation of the Tatalon Estate and the sale of its lots to bona fide occupants.
    • Presidential Decree (P.D.) No. 1261 designated the National Housing Authority (NHA) as the administrator of the Tatalon Estate Housing Project, establishing the framework for lot awards and subsequent property disposition.
  • Award of the Subject Lot to Dolores Maranan
    • In 1983, NHA awarded Lot 3, Block 12 of the Tatalon Estate Urban Bliss Project (TEUBP), covering 65 square meters, to Dolores Maranan because her name appeared on the 1958 Araneta Census of Occupants.
    • Procedural actions included:
      • A Transfer Notice on May 25, 1983, followed by the execution of a Deed of Sale with Mortgage on May 31, 1983.
      • Issuance of Transfer Certificate of Title (TCT) No. 303230 on August 18, 1983, after registration by the Register of Deeds of Quezon City.
      • Subsequent developments: Maranan executing a Special Power of Attorney in December 1984 in favor of Perlita Canedo, full payment in December 1985 leading to the cancellation and release of the mortgage, and Maranan selling the lot to Canedo with TCT No. 127373 later issued.
  • Respondent Soledad C. Pascual’s Claim and Alternative Occupancy
    • Respondent Pascual filed a letter-complaint on February 14, 1983 before the NHA General Manager, asserting that she was the rightful beneficiary as the actual occupant of the lot since 1968.
    • Supporting her claim, Pascual presented:
      • Evidence of residency, including being listed in the 1976 Census and having resided continuously despite the lot being used for other purposes (e.g., operating a motor shop).
      • Details that her domicile was affected when her house was demolished and she was later relocated to an inner lot.
    • Administrative recommendations were divided:
      • The Inspector General (June 20, 1983) recommended awarding the subject lot to Pascual based on her census inclusion and physical evidence of occupation (aerial photo).
      • The Project Manager preferred maintaining the award to Maranan, suggesting respondent be relocated to an inner lot.
    • The General Manager, on October 3, 1983, sided with the Project Manager and dismissed Pascual’s complaint for lack of merit.
  • Administrative and Judicial Proceedings
    • Subsequent Developments:
      • Pascual’s appeal to the Office of the President on December 4, 1984, which eventually received due course via a 1st Indorsement on December 14, 1984, affirming the award’s propriety.
      • On August 4, 1986, a letter from the Presidential Staff Director of the Malacañang Public Assistance Center urged a reconsideration on the grounds that Maranan was an absentee awardee (having become a lawful resident of Honolulu, Hawaii in 1979), suggesting fraudulent circumstances.
    • Efforts to resolve the dispute included a series of conferences and a possible swapping of lots:
      • Pascual signed a Conditional Contract to Sell Lot 2, Block 2 of the TEUBP on February 5, 1987, under protest to preserve her claim on the subject lot.
      • On September 29, 1987, a proposal by the Public Complaints Assistance and Action Center recommended either a new front lot award to Pascual or cancellation of the inner lot award with appropriate financial adjustments.
    • Judicial Relief:
      • On October 19, 1989, Pascual filed a Complaint for declaration of nullity, reconveyance, and damages before the Regional Trial Court of Quezon City.
      • On June 15, 1993, the trial court rendered a Decision in favor of petitioner (NHA) which:
        • Declared Maranan the absolute owner of the subject lot via TCT No. 303230.
ii. Recognized Pascual as the lawful occupant of an inner lot while dismissing her claims regarding the subject lot.
  • Pascual’s subsequent motion for reconsideration was denied, leading her to appeal the case to the Court of Appeals (docketed as CA-G.R. CV No. 45015).
  • Court of Appeals Decision and Subsequent Developments
    • On November 21, 2002, the Court of Appeals set aside the trial court’s ruling by:
      • Declaring the award of the subject lot to Maranan null and void.
      • Ordering the cancellation of TCT No. 303230 and directing the NHA to reconvey the subject lot to Pascual.
    • The NHA’s motion for reconsideration was denied in a Resolution dated May 8, 2003.
    • The instant petition for review raised issues regarding:
      • The power of the courts to nullify the award despite its administrative finality claims.
      • The propriety of reconveying the lot to Pascual.
      • The impact of Pascual’s conditional contract and deed of sale for another lot on her entitlement to the subject lot.
      • Res judicata issues concerning the prior award.
  • Jurisprudential and Policy References
    • Reliance on established cases such as Raymundo v. People’s Homesite and Housing Corporation, Swan v. Court of Appeals, and Teves v. People’s Homesite and Housing Corporation.
    • The application of statutory policies under Section 3 of P.D. No. 1261 and the Code of Policies of the Tatalon Estate Development Project, which provide criteria (including continuous residency and occupancy) for awarding lots.

Issues:

  • Whether the court has the power to nullify the award of Lot 3, Block 12 to Dolores Maranan even after administrative remedies have been pursued.
    • The principal issue is if the award, despite being appealed by Pascual through administrative means, can still be annulled by the courts.
    • Whether the award has attained finality and is beyond judicial review.
  • Whether the order for reconveyance of the subject lot to respondent Pascual is proper.
    • The appropriateness of reconveyance as a remedy given that the deed of sale and issuance of title to Maranan are in question.
    • Whether the mechanism of reconveyance properly addresses the errors in the award.
  • Whether Pascual is estopped from asserting her claim on the subject lot by virtue of having executed a conditional contract to sell and a deed of sale for another lot.
    • If her acceptance of an alternative lot constitutes abandonment of her claim over the subject lot.
    • The implications of her subsequent negotiations and non-abandonment of her claim.
  • Whether the award in question is res judicata due to prior administrative actions and decisions, thereby barring further judicial review.
    • Examination of the timeliness and sufficiency of Pascual’s administrative appeal.
    • The effect of res judicata in cases where administrative decisions have not been rendered final.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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