Case Digest (G.R. No. 158364)
Facts:
National Housing Authority v. Soledad C. Pascual, G.R. No. 158364, November 28, 2007, Supreme Court Third Division, Ynares‑Santiago, J., writing for the Court. The petition challenges the Court of Appeals' November 21, 2002 Decision and May 8, 2003 Resolution in CA‑G.R. CV No. 45015 which reversed the Regional Trial Court of Quezon City, Branch 80, in Civil Case No. Q‑89‑3780 that had dismissed respondent’s complaint for declaration of nullity, reconveyance, and damages.The factual background begins with the expropriation and disposition scheme for the Tatalon Estate established by R.A. No. 2616 and the designation of the National Housing Authority (NHA) as administrator by P.D. No. 1261. Pursuant thereto, NHA awarded Lot 3, Block 12 (65 sq.m.) of the Tatalon Estate Urban Bliss Project to Dolores Sabella Maranan in 1983; a Transfer Notice was issued May 25, 1983, a Deed of Sale with mortgage executed May 31, 1983, and Transfer Certificate of Title (TCT) No. 303230 issued August 18, 1983. Maranan executed a Special Power of Attorney in favor of Perlita Canedo (Dec. 1984); Canedo later paid in full and a cancellation of mortgage was recorded (Oct. 22, 1986), and subsequent title transfers followed.
Soledad C. Pascual filed an administrative letter‑complaint (Feb. 14, 1983) asserting she was the actual occupant since 1968 and was included in the 1976 census; the NHA Inspector General recommended awarding the lot to Pascual (June 20, 1983), but the Project Manager and the General Manager favored awarding it to Maranan (General Manager’s resolution, Oct. 3, 1983). Pascual appealed administratively to the Office of the President (Dec. 4, 1984); NHA’s first indorsement (Dec. 14, 1984) upheld its decision. In Aug. 1986, the Presidential Staff Director informed the NHA that Maranan appeared to be an absentee awardee, allegedly a lawful U.S. resident since 1979, and asked for reconsideration.
Subsequent conferences aimed at homelot swapping occurred; under pressure Pascual signed a Conditional Contract to Sell for Lot 2, Block 2 (Feb. 5, 1987). The Public Complaints Assistance and Action Center (Sept. 29, 1987) recommended awarding Pascual another front lot or, if she insisted on Lot 3, that she substantiate her claim. Failing settlement, Pascual filed a Complaint in the RTC (Oct. 19, 1989) seeking nullity of the award to Maranan, cancellation of TCT No. 303230, reconveyance of the lot, and damages.
The trial court (Branch 80) rendered judgment for defendants Maranan and Canedo (June 15, 1993), declared Maranan owner of Lot 3 by TCT No. 303230, and dismissed Pascual’s complaint; it recognized Pascual’s possession of an interior lot and allowed her to perfect title thereto. Pascual appealed to the Court of Appeals (CA‑G.R. CV No. 45015). While the appeal was pending, Pascual fully paid for Lot 2, Block 2 (Oct. 1998) and NHA executed a Deed of Sale in her favor (Sept. 28, 1999).
The Court of Appeals reversed and set a...(Subscriber-Only)
Issues:
- Did the award to Dolores Maranan attain finality and thus bar judicial relief by res judicata or for failure to exhaust administrative remedies?
- Is respondent Pascual estopped from claiming Lot 3 because she voluntarily executed a conditional contract to sell and later accepted a deed of sale for another lot?
- Was Dolores Maranan disqualified as an awardee (i.e., an absentee awardee) so that the award and TCT No. 303230 could be nullified?
- Was the Court of Appeals correct in ordering NHA to reconvey the subject lot t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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