G.R. No. L-20025; January 31, 1964
FAUSTINO CUNETA, petitioner-appellant, vs. MANUEL CASTAÑEDA, ET AL., respondents-appellees.

FACTS

The case involves conflicting claims over Lot 8, Block 24, of the government-acquired Baclaran Estate, which was to be resold to bona fide occupants. The Rural Progress Administration (RPA), and later its successor the Land Tenure Administration (LTA), awarded Lot 8 to respondent Juan O. De Leon via an agreement to sell in 1948. Petitioner Faustino Cuneta, who was awarded the adjacent Lot 7, protested, claiming he was the bona fide tenant of Lot 8 entitled to a purchase preference. After a hearing, the LTA dismissed Cuneta’s complaint and ordered the execution of a final deed of sale in favor of De Leon.
Cuneta received the LTA’s decision on November 19, 1956, filed a motion for reconsideration on December 15, 1956, and received the denial order on June 13, 1957. Instead of appealing this denial to the Office of the President within the 30-day period prescribed by LTA Administrative Order No. 1, he filed a complaint with another agency and later instituted a petition for certiorari with the Court of First Instance of Rizal on February 26, 1959, alleging grave abuse of discretion by the LTA. The trial court dismissed the petition, prompting this appeal.

ISSUE

Whether the trial court correctly dismissed the petition for certiorari on the grounds of finality of the administrative decision and failure to exhaust administrative remedies.

RULING

Yes, the trial court’s dismissal is affirmed. The core legal logic rests on the binding finality of the LTA’s quasi-judicial decision due to Cuneta’s failure to perfect a timely administrative appeal. Under LTA Administrative Order No. 1, an appeal from the Chairman’s decision to the Office of the President must be taken within 30 days from receipt of the order denying a motion for reconsideration. Cuneta received the denial on June 13, 1957, making his appeal due by July 13, 1957. By filing his judicial action only in 1959, he allowed the LTA decision to become final and executory.
The LTA, as a statutory body, possesses quasi-judicial authority to adjudicate conflicting claims over the lots under its administration. Its duly promulgated rules, like Administrative Order No. 1, have the force of law and are binding on claimants. Consequently, the principle of exhaustion of administrative remedies is not merely a procedural prerequisite but is inextricably linked to prescription in this context. Cuneta’s failure to appeal on time is fatal, as it rendered the LTA decision final, thereby barring his subsequent judicial action under the doctrine of res judicata. A petition for certiorari requires the absence of any plain, speedy, and adequate remedy in the ordinary course of law. Here, the adequate remedy was the appeal to the Office of the President, which Cuneta forfeited. Thus, the trial court correctly dismissed the petition.