GR 164244; (July, 2009) (Digest)
G.R. No. 164244 ; July 30, 2009
NATIONAL HOUSING AUTHORITY, Petitioner, vs. REYNALDO MAGAT, Respondent.
FACTS
The National Housing Authority (NHA) issued a Memorandum on June 26, 1998, resolving a conflict over Lot 53, Block 1 of the Peñafrancia ZIP Project in favor of Armando De Guzman, to the exclusion of respondent Reynaldo Magat. Magat, a censused renter in the project, appealed to the Office of the President, which sustained the NHA’s decision. Magat then elevated the case to the Court of Appeals.
The Court of Appeals reversed the rulings of the NHA and the Office of the President. It found that the lot contained two distinct structures: one purchased by De Guzman from Bonifacio Punzalan and another structure occupied by Magat under a lease from Clarita Punzalan. The appellate court held that Magat, as a censused renter, had a right to purchase the portion of the lot occupied by his rented structure, in line with the social justice objectives of the ZIP Project.
ISSUE
Whether the Supreme Court should grant the NHA’s petition for review.
RULING
The Supreme Court denied the petition. The legal logic is twofold, focusing on mootness and the NHA’s lack of legal standing. First, the Court noted that a separate petition (G.R. No. 164162) filed by the real claimant, Armando De Guzman, assailing the same Court of Appeals decision, had already been denied with finality. This final resolution on the merits of the identical appellate judgment rendered the present petition moot.
Second, and decisively, the Court ruled that the NHA is not a real party in interest entitled to prosecute this action. Under the Rules of Court, a real party in interest is one who stands to be benefited or injured by the judgment and who possesses a material interest in the issue. The NHA, as the administrative agency that merely adjudicated the conflicting claims between two private parties, De Guzman and Magat, has no such material or proprietary interest in the subject property. It does not stand to gain or lose from the judgment over the lot’s ownership. The real parties in interest are the competing claimants, De Guzman and Magat. Since the NHA lacks a cause of action and the substantive issue has been laid to rest in the final resolution of G.R. No. 164162, the petition was denied.