National Development Co vs Hervilla

G.R. No. L-65718. June 30, 1987

Facts
An action for Recovery of Possession and Damages filed on December 20, 1973
against Dole Philippines involving Lots Nos. 3284, and 3288, GSS- 269-D, each
containing four (4) hectares, more or less, situated at Sitio Balisong, Palkan,
Polomolok, South Cotabatoby Wilfredo Hervilla. The trial court rendered a decision
in favor of the petitioners. However, the IAC reversed the decision and ordered
the petitioners to vacate the land. A motion for reconsideration was filed by
petitioners and later a Supplement to the Motion for Reconsideration with Motion
for New Trial was also filed alleging that while the case was pending with
respondent Court, the Bureau of Lands issued the free patents in favor of
Petitioners' predecessor-in-interest. The respondent court denied the motion.

Issue
whether or not the Court in deciding a case involving recovery of possession
declare null and void title issued by an administrative body or office during the
pendency of such case

Ruling
No. It is now well settled that the administration and disposition of public lands
are committed by law to the Director of Lands primarily, and, ultimately, to the
Secretary of Agriculture and Natural Resources. The jurisdiction of the Bureau of
Lands is confined to the determination of the respective rights of rival claimants
to public lands or to cases which involve disposition and alienation of public
lands. The jurisdiction of courts in possessory actions involving public lands is
limited to the determination of who has the actual, physical possession or
occupation of the land in question (in forcible entry cases, before municipal
courts) or, the better right of possession (in accion publiciana in cases before
Courts of First Instance, now Regional Trial Courts).

Topic: Administrative findings generally conclusive

Atlas Consolidated Mining and Development Corp vs Factoran
G.R. No. L-75501. September 15, 1987

Facts
Private respondent Asterio Buqueron registered the declarations of
location of his "St. Mary Fr." and "St. Joseph Fr." mining claims with the same
Mining Recorder of Toledo City. the said mining claims were surveyed and the
survey plans thereof were duly approved by the Director of Mines and Geo
Sciences. Notice of Buqueron's lease application was published in the February
22 and 28, 1977 issues of the Evening Post. During the said period of
publication, petitioner filed an adverse claim against private respondent's mining
claims on the ground that they allegedly overlapped its own mining claims. The
Director of Mines rendered a decision in favor of Buqueron but it was reversed by
the Minister of Natural Resources. on further appeal, the Deputy Executive
Secretary, Office of the President, reversed the decision of the Minister of Natural
Resources and reinstated the decision of the Director of Mines and Geo
Sciences.

Issue
Whether or not there was a valid location and discovery of the disputed mining
claims

Ruling
Yes. Such findings of the Director of Mines, although reversed by the Minister of
Natural Resources, were affirmed by the Office of the President. This Court has
repeatedly ruled that judicial review of the decision of an administrative
official is of course subject to certain guideposts laid down in many decided
cases. Thus, for instance, findings of fact in such decision should not be
disturbed if supported by substantial evidence, but review is justified when there
has been a denial of due process, or mistake of law or fraud, collusion or
arbitrary action in the administrative proceeding, where the procedure which led
to factual findings is irregular; when palpable errors are committed; or when a
grave abuse of discretion, arbitrariness, or capriciousness is manifest.
A careful study of the records shows that none of the above circumstances is
present in this case. On the contrary, in accordance with the prevailing principle
that "in reviewing administrative decisions, the reviewing Court cannot reexamine
the sufficiency of the evidence as if originally instituted therein, and receive
additional evidence, that was not submitted to the administrative agency
concerned," the findings of fact in this case must be respected.