#1 NHA v. Segunda Almeida, CA G.R. No. 162784 June 22, 2007 Facts: The Land Tenure Administration awarded to Margarita Herrera several portions of land in San Pedro, Laguna. She had two children, Francisca and Beatriz (she died before her mom; mother of PR). When Margarita passed away, Francisca executed a deed of self-adjudication claiming that she was the only remaining relative of Margarita. The deed of was based on a 'Sinumpaang Salaysay' allegedly executed by Margarita. The surviving heirs of Beatriz filed a case for annulment of the deed. A decision was rendered and the deed was declared null and void. During the trial, Francisca filed an application with the NHA to purchase the same lots. The NHA granted the application. The PR appealed to the Office of the President. The NHA resolution was affirmed. When Francisca died, her heirs executed an extrajudicial settlement of her estate which they submitted to the NHA. The transfer of rights was approved by the NHA. The heirs of Francisca directed P R to leave the premises that she was occupying. Feeling aggrieved, PR sought the cancellation of the titles issued in favor of the heirs of Francisca. She filed a complaint in the RTC of San Pedro, Laguna. She invoked her 40 year occupation of the property and re-raised the fact that Francisca's declaration is a nullity because the other heirs were disregarded. The RTC dismissed the case for lack of jurisdiction. The CA reversed the decision and remanded the case for further hearing. The RTC rendered a decision setting aside the resolution of the NHA and the decision of the Office of the President. The Regional Re gional Trial Court ruled that 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. The NHA and the heirs of Francisca filed their respective motions which were both denied. The CA affirmed the decision of the trial court. Issues: 1. WON 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. WON the court has jurisdiction to make the award on the subject l ots. 3. WON the decision of NHA is arbitrary. Held: 1. 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 Supreme Court, 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. Court o f Tax Appeals, 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 three (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 1987 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. 2. YES. Petitioner cites Batas Pambansa Blg. 129 or the Judiciary Reorganization Act of 1980 where it is therein provided that the Intermediate Appellate Court (now, Court of Appeals) shall exercise the "exclusive appellate jurisdiction over all final judgments, decisions, resolutions, orders or awards, of the Regional Trial Courts 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 Regional Trial Court has no jurisdiction to rule over awards made by the NHA. Well-within its jurisdiction, the Court of Appeals, in its decision of August 28, 2003, 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 Court of Appeals dated June 26, 1989 (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. 3. YES. The NHA gave due course to the application made by Francisca Herrera without considering that the initial applicant's death would transfer all her property, rights and obligations to the estate including whatever interest she has or may have had over the disputed properties. To the extent of the interest that the original owner had over the property, the same should go to her estate. Margarita Herrera had an interest in the property and that interest should go to her estate upon her demise so as to be able to properly distribute them later to her heirs—in accordance with a will or by operation of law. When the original buyer died, the NHA should have considered the estate of the dec edent as the next "person" likely to stand in to fulfill the obligation to pay the rest of the purchase price. The opposition of other heirs to the repurchase by Francisca Herrera should have put the NHA on guard as to the award of
the lots. Further, the Decision in the said Civil Case No. B-1263 (questioning the Deed o f SelfAdjudication) which rendered the deed therein null and void should have alerted the NHA that there are other heirs to the interests and properties of the decedent who may claim the property after a testate or intestate proceeding is concluded. The NHA ther efore acted arbitrarily in the award of t he lots.
