G.R. No. L-25026 August 31, 1971
HON. JUAN L. UTLEG, as Acting Director of the Bureau of Forestry, HON. JOSE Y. FELICIANO, as Secretary of Agriculture and Natural Resources and the EXECUTIVE SECRETARY, petitioners, vs. HON. FRANCISCO ARCA, as Judge of the Court of First Instance of Manila, Branch I, and the TINDALO TIMBER CORPORATION, respondents.

FACTS

Tindalo Timber Corporation held Ordinary Timber License 181-’63, expiring June 30, 1963. It applied for renewal on June 28, 1963, paying the requisite fees. The District Forester recommended renewal, noting the licensee had not yet met the 60% allowable cut requirement but might do so by the expiry date. On August 8, 1963, the Acting Director of Forestry issued a renewal document, O.T. 642-’64. However, this proposed license was forwarded to the Secretary of Agriculture and Natural Resources for mandatory approval.
Subsequently, the Bureau received a report that Tindalo had cut timber outside its licensed area during the term of its original license. Consequently, the Acting Director requested the return of the proposed renewal from the Secretary, who returned it unapproved. On November 5, 1963, the Director of Forestry formally rejected Tindalo’s renewal application due to the cited violations. Tindalo filed a motion for reconsideration, which was denied. Despite this denial, Tindalo filed a new application for the 1964-1965 period. In 1965, Tindalo filed a court action and secured a writ of preliminary injunction from the CFI of Manila, compelling the forestry officials to allow its logging operations.

ISSUE

Whether the respondent Court of First Instance acted without or in excess of jurisdiction, or with grave abuse of discretion, in issuing a writ of preliminary injunction that allowed Tindalo Timber Corporation to conduct logging operations.

RULING

Yes. The Supreme Court annulled the lower court’s order and writ. The legal logic is anchored on the statutory framework governing timber licenses and the jurisdiction of the Bureau of Forestry. Under Section 1831 of the Revised Administrative Code, the Director of Forestry, with the approval of the Department Secretary, has exclusive authority to issue, renew, or cancel timber licenses. The original license expired by law on June 30, 1963. The purported renewal document dated August 8, 1963, was ineffective because it lacked the required approval of the Secretary of Agriculture and Natural Resources. The Secretary’s subsequent return of the document unapproved rendered the renewal void.
Therefore, upon the expiration of the original license and the valid denial of its renewal application due to violations, Tindalo’s right to operate ceased. The CFI’s writ of preliminary injunction, issued in 1965, effectively revived an expired license and permitted logging without a valid authority. This constituted an unlawful intrusion into the exclusive administrative domain of the Bureau of Forestry. The court acted without jurisdiction, as it cannot arrogate the discretionary power to issue licenses vested by law in an administrative agency. Furthermore, any subsequent renewal would have expired on June 30, 1965, meaning Tindalo had no cause of action when it filed its court petition in August 1965. The injunction was issued against the law and is null and void.