National Housing Authority v. Almeida
REITERATIONFacts
The Antecedents: The Land Tenure Administration (LTA) awarded portions of land in San Pedro, Laguna, to Margarita Herrera in 1959, evidenced by an Agreement to Sell. Margarita Herrera had two daughters: Beatriz Herrera-Mercado and Francisca Herrera. Beatriz predeceased Margarita, leaving heirs, including the private respondent Segunda Almeida. Margarita Herrera died on October 27, 1971. On August 22, 1974, Francisca Herrera executed a Deed of Self-Adjudication, claiming to be the sole surviving daughter and legal heir of Margarita Herrera, based on a "Sinumpaang Salaysay" allegedly executed by Margarita Herrera on October 7, 1960, wherein she stated that should she pass away, the lot in question would be granted to Francisca Herrera or her heirs. The "Sinumpaang Salaysay" was signed by witnesses and notarized. The heirs of Beatriz Herrera-Mercado filed a case for annulment of the Deed of Self-Adjudication, which was declared null and void by the then Court of First Instance of Laguna on December 29, 1980. During the pendency of the annulment case, Francisca Herrera applied with the National Housing Authority (NHA) to purchase the lots, submitting the "Sinumpaang Salaysay." Segunda Almeida protested the application. The NHA, in a Resolution dated February 5, 1986, granted Francisca Herrera's application, finding she had a better preferential right to purchase the lots, noting Margarita Herrera had executed a "Sinumpaang Salaysay" on October 7, 1960, whereby she waived or transferred her rights and interest over the lots to Francisca Herrera, and that Francisca had paid for the lots in full. Segunda Almeida appealed to the Office of the President, which affirmed the NHA Resolution on January 23, 1987. Francisca Herrera died on February 1, 1987. Her heirs executed an extrajudicial settlement, which the NHA approved, executing deeds of sale in their favor and issuing titles. Segunda Almeida filed a Complaint on February 8, 1988, for "Nullification of Government Lot's Award" with the Regional Trial Court (RTC) of San Pedro, Laguna, Branch 31, seeking the cancellation of titles issued to Francisca Herrera's heirs, invoking her forty-year occupation and the prior annulment of the Deed of Self-Adjudication. Procedural History: The RTC dismissed the case for lack of jurisdiction. The Court of Appeals (CA) reversed this, holding the RTC had jurisdiction over title and possession of real property, and remanded the case. After trial, the RTC, in a Decision dated March 9, 1998, set aside the NHA resolution and Office of the President decision, declared the deeds of sale to Herrera's heirs null and void, and ordered the cancellation of titles, ruling that the "Sinumpaang Salaysay" was not an assignment of rights but a disposition of property effective upon death, thus requiring probate. Motions for reconsideration were denied. Both NHA and Herrera's heirs appealed to the CA. The CA denied admission of the heirs' brief and, on August 28, 2003, affirmed the RTC decision, finding the "Sinumpaang Salaysay" to be a will and that the NHA acted arbitrarily. The Petition: The NHA filed a Petition for Review on Certiorari with the Supreme Court, raising issues of finality of administrative decisions, jurisdiction of courts over NHA awards, and arbitrariness of the NHA award.
Issue(s)
Whether the NHA Resolution and the Office of the President Decision attained finality, and if so, whether administrative res judicata bars further determination of preferential rights. Whether the Regional Trial Court has jurisdiction to rule over awards made by the NHA. Whether the award of the subject lots by the NHA was arbitrary.
Ruling
The petition is DENIED. The decision of the Court of Appeals affirming the Regional Trial Court decision is AFFIRMED.
Ratio Decidendi
On the issue of finality of administrative decisions and administrative res judicata: The Supreme Court reiterated that while res judicata applies to judicial and quasi-judicial acts of administrative officers, the doctrine of separation of powers and the expanded jurisdiction of the Supreme Court under the 1987 Constitution empower courts to review acts of government instrumentalities for grave abuse of discretion amounting to lack or excess of jurisdiction. The Court emphasized that quasi-judicial powers are always subject to judicial power held by the courts, and the executive department cannot impose its agency's judgment upon the judiciary. Therefore, the principle of administrative res judicata does not absolutely bar judicial review when there is a showing of grave abuse of discretion. On the issue of the Regional Trial Court's jurisdiction: The Supreme Court affirmed the Court of Appeals' ruling that the RTC has jurisdiction to hear and decide cases involving title and possession to real property within its jurisdiction. This issue had already been settled by a prior final and executory decision of the Court of Appeals, establishing the "law of the case" doctrine. The Court stressed that the system of judicial review should not be misused to evade the operation of a final and executory judgment, and courts are duty-bound to put an end to controversies. On the issue of the arbitrariness of the NHA award: The Supreme Court found the NHA's award to be arbitrary. The Court noted that the "Sinumpaang Salaysay" clearly indicated that its effectivity commenced upon the death of the author, Margarita Herrera, stating, "sakaling ako'y bawian na ng Dios ng aking buhay..." This language signifies a disposition of property to take effect after death, thus constituting a will. Upon Margarita Herrera's death on October 27, 1971, her interests in the property, including the Contract to Sell with the NHA, were transmitted to her estate by operation of law, as provided by Article 774 of the Civil Code. The NHA, in granting the application of Francisca Herrera in 1986, failed to consider that the original applicant had already passed away and that her rights and obligations were transmitted to her estate. Furthermore, the prior annulment of the Deed of Self-Adjudication by the RTC should have alerted the NHA to the existence of other heirs who might claim the property after testate or intestate proceedings. The NHA's act of awarding the lots without considering these factors was deemed arbitrary and contrary to the laws on succession, sales, and obligations.
Main Doctrine
A "Sinumpaang Salaysay" that disposes of property upon the death of the author is considered a will and must undergo probate before it can transfer property, and an administrative agency cannot arbitrarily award lots based on such a document without considering the laws on succession and the existence of other heirs.