Case Summary (G.R. No. 78036-37)
Procedural History
In 1957, Benjamin Labayen applied to purchase the disputed lot, a claim opposed by Cenon Martires, Faustino Morales, and Iluminada Amansec, who raised adverse claims. A special committee recommended the approval of Labayen’s application, which was granted by the PHHC on December 15, 1961. Martires did not appeal this decision, nor did Amansec, while Morales filed an appeal that was ultimately dismissed in 1969, thereby affirming Labayen’s ownership.
Ownership Transfer and Litigation
Labayen completed the purchase of the lot on February 28, 1969, and subsequently registered the property in his name. He filed a complaint for recovery of possession against Martires, Morales, and Amansec on April 20, 1972. Martires contended that Labayen's title was void, claiming to be a bona fide possessor of the land since 1954. Morales also challenged Labayen's title, alleging fraud and disqualification, resulting in the consolidation of both cases.
Trial Court Decision
On October 22, 1982, the trial court ruled in favor of Labayen, ordering the defendants to vacate the premises and awarding Labayen damages. The trial court also dismissed the complaints filed by Morales and Martires. Both parties appealed the decision, but the Court of Appeals affirmed the trial court's ruling. A subsequent attempt by the Court of Appeals to modify its decision in favor of Morales was later reconsidered, reinstating the original ruling.
Petition for Certiorari
Martires filed a petition for certiorari under Rule 45, arguing that he was entitled to the lot and that the respondent court committed grave abuse of discretion in affirming the trial court's decision. However, the court noted that allegations of grave abuse of discretion do not constitute a valid ground for review under said rule, which focuses solely on questions of law.
Exhaustion of Administrative Remedies
The Supreme Court highlighted that Martires did not exhaust his administrative remedies, as he failed to appeal the PHHC’s 1961 decision that awarded the lot to Labayen, which was a crucial oversight. The court emphasized that this failure constituted grounds for the denial of the petition based on the principle of laches, as Martires's inaction over the years undermined the validity of his claims.
Factual Assertions and Legal Findings
The Supreme Court found that Martires's assertion of being a bona fide occupant was not substantiated by evidence. It was noted that he remain
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Case Background
- The case centers around a land dispute in Diliman, Quezon City, involving a lot of only 588 square meters originally owned by the Peoples Homesite and Housing Corporation (PHHC), now the National Housing Authority.
- The dispute arose from the application of Benjamin Labayen to purchase the lot in 1957, which was opposed by Cenon Martires, Faustino Morales, and Iluminada Amansec, each asserting adverse claims.
- A special committee was established to investigate the protests, and on December 12, 1961, it recommended approval of Labayen's application, which the PHHC formally approved on December 15, 1961.
- Only Morales appealed the PHHC's decision to the Office of the President, while Martires and Amansec did not pursue any further action.
- The appeal was dismissed in 1969, affirming Labayen's award of the lot, which he subsequently purchased and registered under TCT No. 137894.
Legal Actions Initiated
- On April 20, 1972, Labayen filed a complaint for recovery of possession (Civil Case No. Q-16475) against Martires, Morales, and Amansec, alleging he was the registered owner and that the defendants had unlawfully occupied the lot.
- Amansec did not respond and was declared in default. Martires claimed Labayen's title was void due to alleged fraud and asserted he was a bona fide possessor since 1954.
- Anna Morales,