Due Process Not Being Party to a Case

In 1973, license was issued to Milagros Matuguina to operate logging businesses under her
group Matuguina Logging Enterprises. MIWPI was established in 1974 with 7 stockholders.
Milagros Matuguina became the majority stockholder later on. Milagros later petitioned to
have MLE be transferred to MIWPI. Pending approval of MLEs petition, Davao Enterprises
Corporation filed a complaint against MLE before the District Forester (Davao) alleging that
MLE has encroached upon the area allotted for DAVENCORs timber concession. The
Investigating Committee found MLE guilty as charged and had recommended the Director
to declare that MLE has done so. MLE appealed the case to the Ministry of Natural
Resources. During pendency, Milagrosa withdrew her shares from MIWPI. Later, MNR
Minister Ernesto Maceda found MLE guilty as charged. Pursuant to the finding,
DAVENCOR and Philip Co requested Maceda to order MLE and/or MIWPI to comply with
the ruling to pay the value in pesos of 2352.04 m 3 worth of timbers. The Minister then issued
a writ of execution against MIWPI. MIWPI filed a petition for prohibition before the Davao
RTC. The RTC ruled in favor of MIWPI and has ordered to enjoin the Minister from pursuing
the execution of the writ. DAVENCOR appealed and the CA reversed the ruling of the RTC.
MIWPI averred that it is not a party to the original case (as it was MLE that was sued a
separate entity). That the issuance of the order of execution by the Minister has been made
not only without or in excess of his authority but that the same was issued patently without
any factual or legal basis, hence, a gross violation of MIWPIs constitutional rights under the
due process clause.
ISSUE: Whether or not MIWPIs right to due process has been violated.
HELD: The SC ruled in favor of MIWPI. Generally accepted is the principle that no man
shall be affected by any proceeding to which he is a stranger, and strangers to a case not
bound by judgment rendered by the court. In the same manner an execution can be issued
only against a party and not against one who did not have his day in court. There is no
basis for the issuance of the Order of Execution against the MIWPI. The same was issued
without giving MIWPI an opportunity to defend itself and oppose the request of DAVENCOR
for the issuance of a writ of execution against it. In fact, it does not appear that MIWPI was
at all furnished with a copy of DAVENCORs letter requesting for the Execution of the
Ministers decision against it. MIWPI was suddenly made liable upon the order of execution
by the respondent Secretarys expedient conclusions that MLE and MIWPI are one and the
same, apparently on the basis merely of DAVENCORs letter requesting for the Order, and
without hearing or impleading MIWPI. Until the issuance of the Order of execution, MIWPI
was not included or mentioned in the proceedings as having any participation in the
encroachment in DAVENCORs timber concession. This action of the Minister disregards
the most basic tenets of due process and elementary fairness. The liberal atmosphere
which pervades the procedure in administrative proceedings does not empower the

presiding officer to make conclusions of fact before hearing all the parties concerned. (1996
Oct 24)