G.R. No. L-55463 November 25, 1983
HON. ROBERTO V. REYES, Deputy Executive Secretary, HON. RONALDO ZAMORA, Assistant Executive Secretary, HON. JOSE LEIDO JR., Secretary of Natural Resources, and HON. RAMON N. CASANOVA, Acting Director of Lands, petitioners, vs. HON. COURT OF APPEALS, JULITO GEOLINA and COLUMBA POL, respondents.

FACTS

Private respondents Julito Geolina and Columba Pol filed a petition for certiorari with the Court of First Instance, challenging the final resolution of the petitioners (Lands Officials) in a conflict over two small public land lots in San Francisco, Agusan del Sur. The lots, measuring 211 and 216 square meters, were commercial in classification. Geolina and Pol claimed actual possession since 1960, having constructed houses and resided thereon. The opposing claimants, Anita Abad Karaos and Benigno Karaos, asserted rights as successors or applicants, alleging the structures were built by them and that possession by Geolina and Pol was merely permissive. The Lands Officials, in conflicting orders, initially favored Geolina and Pol based on their continuous possession but later reversed to favor the Karaos claimants, prompting the court action.
The trial court and the Court of Appeals ruled in favor of Geolina and Pol, ordering the Lands Officials to process their applications for purchase of the lots. The core dispute revolved around the proper mode of sale—whether these commercial lots could be sold via private sale under Republic Act No. 730 , which by its title and Section 1 explicitly applies to public lands for “residential purposes.” The Lands Officials contended that a public auction was required for commercial lots under the Public Land Act.

ISSUE

Whether public land lots classified as commercial, but actually used for residence and small-scale commerce by the occupants, may be sold through private sale under Republic Act No. 730 .

RULING

The Supreme Court affirmed the Court of Appeals, ruling that the lots in question are subject to private sale under R.A. No. 730 . The Court rejected a rigid, literal interpretation that would restrict the law’s application solely to lots formally classified as residential. It emphasized the law’s intent to benefit Filipino citizens who have in good faith established residence on public land. The evidence established that Geolina and Pol were bona fide residents, having lived on the lots since 1960 and constructed their homes there. The commercial classification stemmed from their location in the poblacion, and their use involved small-scale ventures incidental to their residence.
The Court applied the principle of statutory construction that in case of doubt, the lawmaking body is presumed to have intended right and justice to prevail. Denying the application of R.A. No. 730 would be inequitable, as it would deprive the actual resident-occupants of the preference granted by law, forcing them into a public auction against potentially deeper-pocketed commercial speculators. The law’s essence is to secure land for the homeless, and this purpose is not defeated by a dual residential-commercial use on such a small scale. Therefore, public land lots not exceeding 1,000 square meters, used as a residence and for small commercial or industrial purposes, may be sold via private sale under R.A. No. 730 . The petition was dismissed.