G.R. No. 158364 ; November 28, 2007
NATIONAL HOUSING AUTHORITY, Petitioner, vs. SOLEDAD C. PASCUAL, Respondent.

FACTS

The National Housing Authority (NHA) awarded Lot 3, Block 12 of the Tatalon Estate Urban Bliss Project to Dolores Maranan in 1983, based on her inclusion in the 1958 Araneta Census List of Occupants. Maranan subsequently sold the lot to Perlita Canedo. Respondent Soledad Pascual contested this award, claiming she was the actual occupant since 1968, was included in the 1976 census, and had her house demolished and relocated in 1983. An NHA Inspector General recommended awarding the lot to Pascual, but the NHA General Manager upheld Maranan’s award. Pascual appealed to the Office of the President. Investigations later revealed Maranan had been a lawful resident of Hawaii since 1979, indicating she was an absentee awardee. The NHA attempted to settle by offering Pascual an inner lot, which she conditionally accepted under pressure, but no final resolution was reached on Maranan’s disqualification.

ISSUE

Whether the award of the subject lot to Dolores Maranan by the NHA is valid, and whether respondent Soledad Pascual is entitled to the award of the same lot.

RULING

The Supreme Court denied the NHA’s petition and affirmed the Court of Appeals’ decision with modification, ordering the NHA to award the subject lot to Pascual. The legal logic rests on the principle that administrative decisions, while generally final, can be reviewed by the courts when tainted by fraud, collusion, arbitrariness, or grave abuse of discretion. Here, the award to Maranan was fundamentally flawed because she was an absentee awardee, having been a resident of Hawaii since 1979, which was a condition disqualifying her from the award under the governing laws and policies of the Tatalon Estate project. The NHA’s continued insistence on upholding this award despite clear evidence of Maranan’s disqualification constituted grave abuse of discretion. Pascual, as a qualified actual occupant and beneficiary, had a superior right. The Court held that the NHA’s subsequent offer of an inner lot to Pascual did not cure the invalidity of the original award, and Pascual’s conditional acceptance of that inner lot, made under the threat of losing all rights, did not constitute a valid waiver of her claim to the contested front lot. The award to an unqualified person is void, and the qualified beneficiary must be accorded her right.