National Housing Authority v.

Almeida
G.R. No. 162784             June 22, 2007

FACTS:
The Land Tenure Administration (LTA) awarded to Margarita Herrera several portions of
land which are part of the Tunasan Estate in San Pedro, Laguna. The award is evidenced
by an Agreement to Sell. By virtue of RA 3488, the LTA was succeeded by the DAR. In
1975, the DAR was succeeded by the NHA by virtue of PD No. 757. NHA as the
successor agency of LTA is the petitioner in this case.

The records show that Margarita Herrera had two children: Beatriz Herrera-Mercado (the
mother of private respondent) and Francisca Herrera. Beatriz predeceased her mother
and heirs. Margarita Herrera passed away on October 27, 1971.

On August 22, 1974, Francisca Herrera, the remaining child of the late Margarita Herrera
executed a Deed of Self-Adjudication claiming that she is the only remaining relative,
being the sole surviving daughter of the deceased. Also, claimed to be the exclusive legal
heir of the late Margarita Herrera.

The Deed of Self-Adjudication was based on a Sinumpaang Salaysay allegedly

executed by Margarita Herrera. The said document was signed by two witnesses and
notarized. The witnesses signed at the left-hand side of both pages of the document.
Margarita placed her thumbmark above her name in the second page and at the left-hand
margin of the first page of the document.

The surviving heirs of Beatriz Herrera-Mercado filed a case for annulment of the Deed of
Self-Adjudication before the then CFI. Thus, a Decision was rendered and the deed was
declared null and void.

During trial on the merits of the case assailing the Deed of Self-Adjudication, Francisca
filed an application with the NHA to purchase the same lots submitting a copy of the
"Sinumpaang Salaysay" executed by her mother. Private respondent Almeida, as heir of
Beatriz, protested the application.

NHA granted the application of Francisca – since Margarita executed the said document
where she waived or transferred all her rights and interest over the lots in question in
favor of the protestee and the latter paid the lots in question in full with the defunct LTA.

Office of the President affirmed the NHA resolution.

When Francisca died, her heirs executed an extrajudicial settlement of her estate which
they submitted to the NHA. Said transfer of rights was approved by the NHA. The NHA
executed several deeds of sale in favor of the heirs of Francisca and titles were issued in
their favor. Thereafter, the heirs of Francisca directed Segunda Mercado-Almeida to
leave the premises that she was occupying.
Aggrieved by the decision of the OP, private respondent Segunda Almeida sought the
cancellation of the titles issued in favor of the heirs of Francisca. She filed a Complaint for
"Nullification of Government Lot's Award," with the RTC. In her complaint, private
respondent invoked her 40-year occupation of the disputed properties, and re-raised the
fact that Francisca’s declaration of self-adjudication has been adjudged as a nullity
because the other heirs were disregarded. The defendant heirs of Francisca alleged that
the complaint was barred by laches and that the decision of the OP was already final and
executory. Also, they contended that the transfer of purchase of the subject lots is
perfectly valid as the same was supported by a consideration and that Francisca paid for
the property with the use of her own money. Further, argued that plaintiff's occupation of
the property was by mere tolerance and that they had been paying taxes thereon.

The RTC dismissed the case for lack of jurisdiction; CA: reversed the RTC since the case
involving "title and possession to real property within its jurisdiction." Thus, the case
should be remanded for further proceedings on the merits.

With this, the RTC rendered a Decision setting aside the resolution of the NHA and the
decision of the OP. It declared the deeds of sale executed by NHA in favor of Herrera's
heirs null and void. The Register of Deeds of Laguna was ordered to cancel the TCT
issued. Similarly, the "Sinumpaang Salaysay" was not an assignment of rights but a
disposition of property which shall take effect upon death. It then held that the said
document must first be submitted to probate before it can transfer property. MR denied

The CA affirmed the decision of the RTC; and denied admission by the court in a
Resolution for being a "carbon copy" of the brief submitted by the NHA and for being filed
(79) days late.

ISSUE:
WON THE PRINCIPLE OF ADMINISTRATIVE RES JUDICATA APPLIES?

RULING:
No. Res judicata is a concept applied in review of lower court decisions in accordance
with the hierarchy of courts. But jurisprudence has also recognized the rule of
administrative res judicata: "the rule which forbids the reopening of a matter once
judicially determined by competent authority applies as well to the judicial and quasi-
judicial facts of public, executive or administrative officers and boards acting within their
jurisdiction as to the judgments of courts having general judicial powers . . . It has been
declared that whenever final adjudication of persons invested with power to decide on the
property and rights of the citizen is examinable by the SC, upon a writ of error or
a certiorari, such final adjudication may be pleaded as res judicata."

To be sure, early jurisprudence were already mindful that the doctrine of res

judicata cannot be said to apply exclusively to decisions rendered by what are usually
understood as courts without unreasonably circumscribing the scope thereof and that the
more equitable attitude is to allow extension of the defense to decisions of bodies upon
whom judicial powers have been conferred.
In Ipekdjian Merchandising Co., Inc. v. CTA, the Court held that the rule prescribing that
"administrative orders cannot be enforced in the courts in the absence of an express
statutory provision for that purpose" was relaxed in favor of quasi-judicial agencies.

In fine, it should be remembered that quasi-judicial powers will always be subject to true
judicial power that which is held by the courts. Quasi-judicial power is defined as that
power of adjudication of an administrative agency for the "formulation of a final order."
This function applies to the actions, discretion and similar acts of public administrative
officers or bodies who are required to investigate facts, or ascertain the existence of
facts, hold hearings, and draw conclusions from them, as a basis for their official action
and to exercise discretion of a judicial nature. However, administrative agencies are not
considered courts, in their strict sense. The doctrine of separation of powers reposes the
three great powers into its (3) branches: the legislative, the executive, and the judiciary.
Each department is co-equal and coordinate, and supreme in its own sphere.
Accordingly, the executive department may not, by its own fiat, impose the judgment of
one of its agencies, upon the judiciary. Indeed, under the expanded jurisdiction of the
Supreme Court, it is empowered to "determine whether or not 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." Courts have an expanded role under the
Constitution in the resolution of societal conflicts under the grave abuse clause of Article
VIII which includes that duty to check whether the other branches of government
committed an act that falls under the category of grave abuse of discretion amounting to
lack or excess of jurisdiction.

Petitioner cites BP Blg. 129 or the Judiciary Reorganization Act of 1980 where it is
provided that the IAC (now, CA) shall exercise the "exclusive appellate jurisdiction over
all final judgments, decisions, resolutions, orders or awards, of the RTC and Quasi-
Judicial agencies, instrumentalities, boards or commissions, except those falling within
the jurisdiction of the Supreme Court in accordance with the Constitution' " and contends
that the RTC has no jurisdiction to rule over awards made by the NHA.

Well-within its jurisdiction, the CA, in its decision, already ruled that the issue of the trial
court's authority to hear and decide the instant case has already been settled in the
decision of the CA, which has become final and executory on August 20, 1989 as per
entry of judgment dated October 10, 1989. We find no reason to disturb this ruling.
Courts are duty-bound to put an end to controversies. The system of judicial review
should not be misused and abused to evade the operation of a final and executory
judgment. The appellate court's decision becomes the law of the case which must be
adhered to by the parties by reason of policy.