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NATIONAL HOUSING AUTHORITY v. SEGUNDA ALMEIDA

FACTS:

Margarita Herrera received several portions of land in Tunasan Estate from the Land Tenure Administration (LTA). After her death, her daughter, Francisca Herrera, claimed to be the sole heir through a Deed of Self-Adjudication. However, the deed was later declared null and void. During the trial, Francisca applied to purchase the same lots from the National Housing Authority (NHA) using a "Sinumpaang Salaysay" as evidence. The NHA granted Francisca's application, considering the evidence and records of the lots.

Private respondent Segunda Mercado-Almeida filed a complaint to nullify the government lot's award against the heirs of Francisca Herrera. Almeida argued that the self-adjudication was invalid due to the disregard of the other heirs. The defendant heirs claimed that the complaint was barred by laches and that the decision of the Office of the President was final. They also argued that the purchase of the property was valid and supported by consideration. Initially, the Regional Trial Court dismissed the case for lack of jurisdiction, but the Court of Appeals reversed the decision. At trial, the Regional Trial Court declared the deeds of sale executed by the NHA in favor of Herrera's heirs null and void, stating that the "Sinumpaang Salaysay" needed to undergo probate to transfer property. The motions for reconsideration filed by the NHA and the heirs were denied. Both parties appealed to the Court of Appeals, but the heirs' brief was denied admission for being a "carbon copy" of the NHA's brief and for being filed late. The Court of Appeals affirmed the decision of the Regional Trial Court.

ISSUES:

  1. Whether or not the resolution of the NHA and the decision of the Office of the President have attained finality, and if so, whether or not the principle of administrative res judicata bars the court from further determining who between the parties has preferential rights for award over the subject lots;

  2. Whether or not the court has jurisdiction to make the award on the subject lots;

  3. Whether or not the award of the subject lots by the NHA is arbitrary.

  4. Whether the Regional Trial Court has jurisdiction to rule over awards made by the National Housing Authority (NHA).

  5. Whether the NHA's resolution awarding the purchase of lots to the daughter of the original awardee was done arbitrarily.

  6. Whether the "Sinumpaang Salaysay" document is a will and whether it binds the NHA.

  7. Whether the interests of the decedent over the property should transfer by virtue of an operation of law or by virtue of a resolution by the NHA.

  8. Whether the National Housing Authority (NHA) acted arbitrarily in the award of the lots despite the opposition of other heirs and the nullification of the deed of self-adjudication.

  9. Whether the validity of the will is an issue for the probate court to determine.

RULING:

  1. The court ruled in favor of the respondents. The doctrine of administrative res judicata applies to the present case, and the court has jurisdiction to determine the preferential rights for award over the subject lots. The award of the subject lots by the NHA was found to be arbitrary.

  2. The Court of Appeals has already ruled that the Regional Trial Court has jurisdiction to hear and decide the case. This ruling has become final and executory and must be adhered to by the parties.

  3. The Court finds no merit in the NHA's argument that the award was not done arbitrarily. The NHA failed to consider that the original awardee had passed away and that her property interests should have been transferred to her estate.

  4. The "Sinumpaang Salaysay" document is not a will and does not bind the NHA. However, the interests of the decedent over the property should transfer to her estate by virtue of an operation of law.

  5. The interests of the decedent should transfer to her estate by virtue of an operation of law, and not by virtue of a resolution by the NHA. The NHA should have considered the estate of the decedent as the next "person" likely to fulfill the obligation to pay the rest of the purchase price.

  6. The NHA acted arbitrarily in the award of the lots considering the opposition of other heirs and the nullity of the deed of self-adjudication.

  7. The validity of the will is a matter for the probate court to decide.

PRINCIPLES:

  • Administrative res judicata can be applied to decisions made by administrative officers and boards. It prevents the reopening of a matter once judicially determined by competent authority.

  • Quasi-judicial agencies have the power of adjudication but are not considered courts. Their decisions can be subject to review by the courts.

  • The separation of powers reposes the three great powers into the legislative, executive, and judiciary branches, each co-equal and coordinate, and supreme in its own sphere.

  • The expanded jurisdiction of the Supreme Court empowers it to determine whether there has been grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the government.

  • The Court of Appeals exercises exclusive appellate jurisdiction over all final judgments, decisions, resolutions, orders, or awards of Regional Trial Courts and Quasi-Judicial agencies, except those falling within the jurisdiction of the Supreme Court.

  • Courts have a duty to put an end to controversies and the system of judicial review should not be misused to evade the operation of a final and executory judgment.

  • The death of a person does not extinguish their interest over a property, and such interest should go to their estate to be properly distributed to heirs.

  • Obligations are transmissible and may be fulfilled by the estate of the decedent.

  • The opposition of other heirs and the nullity of a deed should put authorities on guard regarding the award of properties.

  • The probate court has jurisdiction over issues concerning the validity of a will.