G.R. No. L-28141. March 16, 1988.
HONORATA B. MANGUBAT, petitioner, vs. HON. ANTONIO J. VILLEGAS, City Mayor of Manila; M. CUDIAMAT, City Treasurer of Manila; GAUDENCIO STA. ANA, Market Administrator, City of Manila; ISAIAS ARCENA, Market Administrator, Central Market, City of Manila; and DOMINADOR BARREDO, respondents.

FACTS

Market stall PS-16-B at the Manila Central Market was originally registered in the name of Benito Barredo. Upon his death, the right to occupy the stall passed to his surviving spouse, Valentina de la Paz, pursuant to the Manila Market Code. Valentina de la Paz actively managed the stall until her death at an advanced age. During her lifetime, she authorized her grandson, respondent Dominador Barredo, to occupy the stall for her and even executed an affidavit purporting to pass her rights to him.
Following Valentina’s death, a dispute arose between petitioner Honorata B. Mangubat (daughter of Benito and Valentina) and respondent Dominador Barredo (grandson) over the right to succeed to the stall. The City Mayor of Manila intervened and ruled that petitioner was disqualified from occupying the stall because her unmarried daughter, who lived with her, was already a registered holder of several stalls in the same market. The Court of First Instance of Manila dismissed petitioner’s suit, upholding the Mayor’s decision and favoring Dominador Barredo based on findings that he lived with and supported his grandmother, Valentina. Petitioner appealed to the Supreme Court on pure questions of law.

ISSUE

The core issue is whether either the petitioner, Honorata B. Mangubat, or the respondent, Dominador Barredo, has a valid right to succeed to the occupancy of Market Stall PS-16-B following the death of the original stallholder’s spouse, Valentina de la Paz, under the Manila Market Code.

RULING

The Supreme Court dismissed the appeal. The Court agreed with the lower court’s denial of petitioner Mangubat’s claim. Under Section 20 of the Manila Market Code, as amended, succession to a market stall is strictly limited. Upon the death of a stallholder, the right passes first to the surviving spouse if living together. If there is no spouse, it passes to the eldest legitimate child upon whom devolves the support of the family. Critically, Section 13 of the same Code disqualifies any person who is already a stallholder from holding another stall. Since it was established that petitioner’s daughter (and by extension, petitioner herself under the circumstances) was already a registered stallholder, petitioner was legally disqualified from succeeding to the disputed stall.
However, the Court reversed the lower court’s award of the stall to respondent Dominador Barredo. The legal logic is clear: the Market Code’s provisions on succession are exclusive and enumerative. The right devolves only to the surviving spouse or, in default thereof, to the eldest legitimate child supporting the family. A grandson, like Dominador Barredo, is not among the enumerated successors under the law. Therefore, he acquired no legal right to the stall through the affidavit executed by his grandmother. Consequently, the stall was correctly declared vacant by the City Mayor. The Court ordered the stall open for new bids, subject to the qualification that if the current occupant, Aurelia Andres, held it under a valid bid, her occupancy should be respected.