G.R. No. 44753 - Francisco vs. Consing

The dispute centers on a parcel of land known as Block 4, Lot 31, Area H, San Rafael I, City of San Jose del Monte, Bulacan (the “subject lot”).
Respondents, spouses Franklin A. Antonio and Esmeralda S. Antonio, claim to have occupied and owned the lot since 1983 as beneficiaries under the Sapang Palay Resettlement Project of the National Housing Authority (NHA).
Petitioners, Pastor Jose Sy, Jesus the Son of God Christian Ministry, and all other persons acting on their behalf, were allowed to use the lot for church activities following an arrangement with respondents.

In 1984 the respondents applied as beneficiaries of the NHA housing project and were later confirmed as qualified beneficiaries in 1989.
In 1990, respondent Esmeralda Antonio joined the Jesus the Son of God Christian Ministry.
In 1992, on respondents’ request, the subject lot was used for church activities. During this period:

A Kasunduan dated January 5, 1992 allegedly indicated respondents’ intention to donate the lot to petitioners.
A Deed of Donation dated January 6, 1992 was executed, purporting to transfer respondent Franklin Antonio’s rights, interests, and obligations over the lot.
A Letter dated January 15, 1992 reinforced the purported donation.

In 1997, a Deed of Absolute Sale was executed in which respondents sold their rights over the lot to petitioners for P30,000.00.
Despite the NHA officially approving respondents’ application and executing the Contract to Sell on April 27, 2000, petitioners continued to claim ownership by paying monthly installments from 2000 to 2010.

The arrangement for petitioners to use the lot was conditioned on the understanding that the lot would be vacated whenever respondents or their children needed it.
In April 2012, Esmeralda Antonio informed petitioners that her children required the lot.
Petitioners, claiming ownership through the disputed donation and sale documents, refused to vacate the property.
Respondents, after sending demand letters and failing to secure voluntary vacatur, initiated a complaint for unlawful detainer.

The Municipal Trial Court in Cities (MTCC) ruled on January 24, 2013, denying petitioners’ right to possess based on the void nature of the Deed of Donation and the Deed of Absolute Sale.

The MTCC held that respondents, as authorized occupants by the NHA, were entitled to possession.
It found that the donation and sale documents were fatally defective for reasons including lack of acceptance and violation of the requirements for transferring future property.

The Regional Trial Court (RTC), Branch 20, Malolos City, Bulacan, affirmed the MTCC’s decision.
On appeal, the Court of Appeals (CA) confirmed the findings of the lower courts, reiterating that the only proper issue in an unlawful detainer case is the right to actual physical possession.
Petitioners filed a Petition for Review on Certiorari under Rule 45, arguing that the executed documents constituted a waiver by respondents of their rights over the lot.

Whether the petitioners’ claim to possession based on the Deed of Donation and the Deed of Absolute Sale is valid despite the apparent irregularities and non-compliance with formal legal requirements.

Whether these documents, even if they purported to transfer rights, could operate to vest in petitioners the right to possess the property.
Whether such transfers are effective despite respondents not having acquired full ownership at the time of the alleged donation or sale.

Whether respondents, as qualified beneficiaries of the NHA housing project and proper occupants of the subject lot, have a superior right to physical possession.
Whether the principle of in pari delicto applies to bar respondents from recovering possession for actions taken in violation of the statutory scheme governing the disposition of homelots under RA 6026/RA 7279.