Petitioner
National Housing Authority
Respondent
Grace Baptist Church
Citation
G.R. No. 156437
Court
Supreme Court
Division
First Division
Ponente
Ynares-Santiago, J.
Decided
March 1, 2004

Summary

Grace Baptist Church sought to compel the National Housing Authority to sell two lots based on an alleged contract. The Church took possession and improved the property after NHA initially granted their request and later approved the sale via Board Resolution. However, when the Church tendered payment at a lower amount based on field office computation, NHA refused citing insufficient payment. The Supreme Court ruled no perfected contract existed since the Church never accepted NHA's official offer of P700 per square meter. The Court applied Civil Code provisions on inexistent contracts and good faith improvements, rejecting equity arguments and estoppel claims against the government. The case was remanded to determine proper compensation under Article 448 regarding buildings constructed in good faith on another's land.

Statutes applied

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By the Intellegal Editorial Board · March 1, 2004

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