Rosete vs. Briones

A party who merely files a motion for reconsideration with an administrative agency but fails to file a timely appeal to the Office of the President within the reglementary period after denial of said motion cannot subsequently challenge the finality of the agency's decision; moreover, a non-party to an administrative appeal cannot collaterally attack the final judgment therein by filing a motion for reconsideration long after the decision has become final and executory.

The National Housing Authority (NHA) owned a 152-square meter lot located at 1014 Estrada Street, Malate, Manila, occupied by several families including petitioner Teodorico Rosete (recorded as residing owner) and respondents Felix Briones, Neorimse Corpuz, and Jose Rosete (recorded as lessees). Following a 1987 census survey, the NHA initially awarded the entire lot to Teodorico, who subsequently paid the full purchase price and real property taxes. However, the other occupants objected, leading the NHA to cancel the original award in 1994 and subdivide the lot among the claimants, allocating 62 square meters to Teodorico and smaller portions to the respondents.

• The subject lot is a 152-square meter property located at 1014 Estrada Street, Malate, Manila owned by the National Housing Authority (NHA).
• A July 30, 1987 census survey conducted by the NHA identified Ricardo Dimalanta, Sr. as absentee structure owner, Felix Briones and Neorimse Corpuz as lessees, Teodoro Rosete as residing owner, and Jose Rosete as lessee.
• The NHA initially awarded the entire 152-square meter lot to petitioner Teodorico P. Rosete (also referred to as Teodoro Rosete).
• In 1990, a Declaration of Real Property was issued in Teodorico's name, and on March 21, 1991, he made full payment of P43,472.00 for the lot and paid the corresponding real property taxes.
• Respondents (Spouses Jose and Remedios Rosete, Neorimse and Felicitas Corpuz, and Felix and Marietta Briones) objected to the award, claiming it was erroneous.
• In an August 5, 1994 Letter-Decision, the NHA cancelled the original award to Teodorico and subdivided the lot as follows: 62 square meters to Teodorico, 40 square meters to the Brioneses, 25 square meters to the Rosetes, 15 square meters to the Corpuzes, and 10 square meters for an easement/pathwalk.
• The NHA informed Teodorico that his excess payments would not be refunded but would be applied to his co-awardees' amortizations, and that the matters were final subject to appeal to the Office of the President within 30 days.
• Teodorico received the August 5, 1994 Letter-Decision on September 24, 1994.
• On October 18, 1994, Teodorico sent a letter to the NHA protesting the cancellation and seeking reconsideration, claiming it was unfair and confiscatory.
• On October 24, 1994, the Rosetes and Corpuzes appealed the NHA decision to the Office of the President (O.P. Case No. 5902).
• On February 2, 1995, Teodorico filed an undated letter in O.P. Case No. 5902 manifesting his assent to the 62-square meter allocation but seeking reimbursement of purchase price and taxes from his co-awardees.
• On November 19, 1997, the Office of the President dismissed the appeal in O.P. Case No. 5902 for being filed out of time, and on March 27, 1998, declared the decision final and executory.
• On July 28, 1999, Teodorico, the Rosetes, and the Corpuzes sent a letter to the NHA seeking approval to subdivide the lot on an "as is, where is" basis to avoid demolition of existing structures.
• In a November 12, 1999 Letter-Reply, the NHA denied the request and retained the original awards, advising the parties to hire a surveyor.
• On May 7, 2003, Teodorico filed a letter cum motion for reconsideration with the Office of the President seeking reconsideration of the November 19, 1997 Decision, claiming the NHA's August 5, 1994 Letter-Decision was null and void for violating PD 1517 and PD 2016.
• On September 8, 2003, the Office of the President denied the motion for reconsideration, stating the November 19, 1997 Decision had become final and executory and that the NHA decision was valid pursuant to NHA Circular No. 13.

• Teodorico's October 18, 1994 letter to the NHA (allegedly mailed September 24, 1994) should be treated as a timely appeal to the Office of the President filed within the 30-day reglementary period under Section 1 of Administrative Order No. 18, Series of 1987, not merely a motion for reconsideration.
• Since the Office of the President never acted on Teodorico's October 18, 1994 letter, his appeal remained pending and he was not bound by the November 19, 1997 Decision in O.P. Case No. 5902 which only dismissed the appeal filed by the Rosetes and Corpuzes.
• The Court of Appeals erred in failing to look into the merits of Teodorico's claim, specifically that the NHA erred in subdividing the lot without accurate survey and without reviewing sketch plans showing existing structures, which would result in unwarranted destruction of homes.
• The respondents were mere renters or lessees not entitled to own portions of the lot under PD 1517 and PD 2016, rendering the NHA's August 5, 1994 Letter-Decision null and void.
• Petitioners sought reimbursement/refund from respondents for overpayments and real estate taxes advanced, with interest, to prevent unjust enrichment.

• The Rosetes argued that the NHA's August 5, 1994 Letter-Decision was erroneous and unjust because it unduly benefited the Brioneses by increasing their lot area while decreasing others', resulting in destruction of existing homes.
• The Corpuzes contended that Teodorico's October 18, 1994 letter could not be treated as an appeal to the Office of the President, and the NHA's failure to act on it should be construed as an implied denial requiring further legal steps.
• The Corpuzes objected to paying interest on the purchase price and taxes advanced by Teodorico, claiming it was unjust.
• The Brioneses adopted the decisions of the NHA, Office of the President, and Court of Appeals, stressing that the Office of the President's disposition had long become final and executory and that courts cannot interfere with the NHA's discretion in awarding lots absent grave abuse of discretion.

• Procedural:
  • Whether the Court of Appeals erred in ruling that petitioner Teodorico Rosete did not file a timely appeal from the National Housing Authority's August 5, 1994 Letter-Decision.
  • Whether the Court of Appeals erred in ruling that the Office of the President's November 19, 1997 Decision against the appeal of Remedios Rosete and Felicitas Corpuz binds petitioner Teodorico Rosete.
  • Whether Teodorico had the legal personality to intervene in O.P. Case No. 5902 and file a motion for reconsideration therein on May 7, 2003.
• Substantive Issues:
  • Whether the National Housing Authority's August 5, 1994 Letter-Decision reallocating the subject lot is valid despite petitioners' claim that respondents were mere lessees ineligible for awards under PD 1517 and PD 2016.
  • Whether petitioners are entitled to reimbursement from respondents for overpayments of purchase price and real property taxes, and subdivision of the lot on an "as is, where is" basis.

• Procedural:
  • The Supreme Court held that Teodorico's October 18, 1994 letter was properly a motion for reconsideration of the NHA's August 5, 1994 Letter-Decision, not an appeal to the Office of the President.
  • The NHA's November 12, 1999 Letter-Reply constituted a denial of Teodorico's motion for reconsideration, after which he should have filed an appeal with the Office of the President within the prescribed period.
  • Teodorico failed to timely appeal the NHA decisions, rendering the August 5, 1994 Letter-Decision final and executory as against him.
  • Teodorico had no personality to intervene in O.P. Case No. 5902 because he was not a party (appellant or otherwise) in that case; thus, his May 7, 2003 letter cum motion for reconsideration was properly denied by the Office of the President and affirmed by the Court of Appeals.
  • The Court affirmed the principle that once a decision has become final and executory, it can no longer be modified or disturbed, and it becomes the ministerial duty of the proper body to order its execution.
• Substantive:
  • The Court declined to discuss the merits of petitioners' claim regarding the validity of the NHA's reallocation and the eligibility of respondents as beneficiaries, noting that petitioners themselves declared they were not questioning the respondents' right to be potential beneficiaries and were satisfied with the 62-square meter allocation to Teodorico.
  • The Court held that it could not order a refund of Teodorico's overpayments because: (1) NHA cannot be ordered to refund as Teodorico never prayed to recover from it but only sought reimbursement from co-awardees; (2) the specific amount of overpayment is not fixed or determinable from the record; and (3) the Supreme Court is not a trier of facts and cannot receive evidence to determine the amounts.
  • However, the Court recognized that petitioners are entitled to be indemnified for paying for the value of the lot and real property taxes over and above what was awarded to them, pursuant to Article 1236 of the Civil Code (whoever pays for another may demand from the debtor what he has paid) or by applying the principle of solutio indebiti under Articles 2154 and 2155 of the Civil Code.

• Finality of Administrative Decisions — Once a decision of an administrative agency has become final and executory, it can no longer be modified or otherwise disturbed, and it becomes the ministerial duty of the proper judicial or quasi-judicial body to order its execution. The Court applied this to bar Teodorico's collateral attack on the NHA's August 5, 1994 Letter-Decision which had become final due to his failure to timely appeal.
• Exhaustion of Administrative Remedies — A party must comply with the prescribed procedure for appealing administrative decisions (filing an appeal with the Office of the President within the reglementary period) before seeking judicial review. The Court emphasized that filing a motion for reconsideration with the agency does not toll the appeal period indefinitely; an appeal must still be filed within the prescribed period after denial of the motion.
• Intervention in Administrative Proceedings — A person who is not a party to an administrative appeal (neither appellant nor respondent) lacks the legal personality to intervene therein and cannot file motions for reconsideration of the final judgment. The Court held Teodorico could not impugn the correctness of the November 19, 1997 judgment in O.P. Case No. 5902 because he was not a party thereto.
• Solutio Indebiti — The civil law principle that creates an obligation to return something received when there is no right to demand it and it was unduly delivered through mistake. The Court cited Articles 2154 and 2155 of the Civil Code as alternative bases for petitioners' claim for reimbursement of overpayments, alongside Article 1236.
• Payment for Another (Article 1236 Civil Code) — Whoever pays for another may demand from the debtor what he has paid, except that if he paid without the knowledge or against the will of the debtor, he can recover only insofar as the payment has been beneficial to the debtor. The Court applied this to recognize petitioners' entitlement to indemnification from co-awardees for overpayments of purchase price and taxes.

• "Generally, once a decision has become final and executory, it can no longer be modified or otherwise disturbed. Thus, it is the ministerial duty of the proper judicial or quasi-judicial body to order its execution, except when, after the decision has become final and executory, facts and circumstances would transpire which render the execution impossible or unjust."
• "He cannot impugn the correctness of a judgment not appealed from by him. He cannot assign such errors as are designed to have the judgment modified."
• "Whoever pays for another may demand from the debtor what he has paid, except that if he paid without the knowledge or against the will of the debtor, he can recover only insofar as the payment has been beneficial to the debtor." (citing Article 1236 of the Civil Code)

• Cruz v. Manila International Airport Authority, G.R. No. 184732, September 9, 2013 — Cited for the principle that a person cannot impugn the correctness of a judgment not appealed from by him and cannot assign errors designed to have the judgment modified.
• Medida v. Court of Appeals, G.R. No. 98334, May 8, 1992 — Cited as the source of the principle affirmed in Cruz regarding the inability of non-parties to challenge judgments.

• Article 1236 of the Civil Code — Provides that whoever pays for another may demand from the debtor what he has paid, subject to limitations if payment was without knowledge or against the will of the debtor; cited as basis for petitioners' entitlement to indemnification.
• Articles 2154 and 2155 of the Civil Code — Define solutio indebiti (obligation to return something unduly delivered through mistake) and its application to payments made by reason of a mistake in the construction or application of a doubtful or difficult question of law; cited as alternative basis for reimbursement.
• Section 1 of Administrative Order No. 18, Series of 1987 — Prescribes the 30-day period for appealing decisions to the Office of the President and provides that the time during which a motion for reconsideration has been pending with the ministry/agency shall be deducted from the period for appeal.
• Presidential Decree No. 1517 (The Urban Land Reform Act) — Invoked by petitioners as allegedly violated by the NHA's reallocation, though the Court did not rule on this substantive issue due to finality of the administrative decision.
• Presidential Decree No. 2016 — Prohibits eviction of occupant families from land identified as Areas for Priority Development or Urban Land Reform Zones; invoked by petitioners but not ruled upon by the Court on the merits.