G.R. No. L-25874 February 28, 1969
MANUEL C. CASTAÑEDA, as Chairman of the Land Tenure Administration, et al., petitioners, vs. THE HON. COURT OF APPEALS, ET AL., respondents.

FACTS

The government acquired and subdivided the Baclaran Estate in Parañaque, Rizal, under Commonwealth Act No. 539 . Mariano Vizcarra was a tenant on the estate occupying Lot 21-B. A portion of this lot, designated as Lot 13-A, was applied for in the name of his daughter, Juanita Vizcarra. On April 23, 1948, the Rural Progress Administration (RPA) executed an agreement to sell Lot 13-A to Juanita, and she paid the lot in full on May 3, 1948, although no final deed of sale was executed. On July 6, 1954, Simplicio Almando wrote to the Bureau of Lands (which had taken over administration) claiming he, not Juanita, was the actual occupant of Lot 13-A and protesting its sale to her. An investigation was held. The case was later transferred to the Land Tenure Administration (LTA) as LTA Case No. 124. The LTA Chairman, Manuel C. Castañeda, decided that Juanita never occupied Lot 13-A, that Almando was the actual occupant, and thus had the preferential right to purchase. He ordered the agreement with Juanita cancelled and her payment refunded. This decision was affirmed by the Office of the President. Juanita then filed an action in the Court of First Instance of Rizal to set aside the LTA decision and compel execution of a deed of sale in her favor. The trial court, based on the evidence from the administrative investigation, also held Almando (substituted by his heirs) was the actual occupant and entitled to preference, dismissing Juanita’s action. The Court of Appeals reversed, declaring Juanita entitled to priority, primarily on the basis that Almando was not an occupant in good faith. Almando’s heirs petitioned the Supreme Court for review.

ISSUE

Whether Simplicio Almando, as the actual occupant of Lot 13-A, is entitled to priority over Juanita Vizcarra in purchasing the lot under the government’s resale program for acquired estates ( Commonwealth Act No. 539 ).

RULING

The Supreme Court REVERSED the decision of the Court of Appeals and AFFIRMED the decision of the Court of First Instance, declaring Simplicio Almando entitled to priority in the purchase of Lot 13-A. The Court held that the factual findings of the executive authorities (LTA and Office of the President) were binding on the courts in the absence of fraud, imposition, or mistake other than error of judgment. These findings established that: (1) Almando was the actual occupant of the lot; (2) he declared the house on the lot for taxation in 1945; (3) Juanita Vizcarra never occupied the lot; (4) the Vizcarras had already purchased other lots in the estate totaling 508 square meters; and (5) Lot 13-A was not part of the lot (21-B) originally leased to Mariano Vizcarra. The Court found the Court of Appeals’ conclusion that Almando was not in good faith unwarranted. Good faith is presumed, and tolerance by Mariano Vizcarra did not constitute bad faith, especially since Lot 13-A was not part of Vizcarra’s leased lot. Since Almando was the actual occupant and the Vizcarras were not, he was entitled to priority. Furthermore, Mariano Vizcarra never applied for Lot 13-A; Juanita did, but she was neither a former lessee nor the actual occupant, so she could not claim a right under regulations favoring tenants’ families.