G.R. No. L-23533 January 30, 1970
LEONARDO T. JOSON and MIGRADEL DEL BARRIO VDA. DE SINAGUINAN, petitioners-appellants, vs. THE SECRETARY OF AGRICULTURE AND NATURAL RESOURCES and THE SOCIEDAD AGRICOLA DE BALARIN, respondents-appellees.

FACTS

The case originated from an investigation by the Bureau of Lands concerning Sales Application No. 6541 of respondent Sociedad Agricola de Balarin, covering approximately 459 hectares in Balarin, Cabanatuan, Nueva Ecija. The Director of Lands issued orders on January 21, 1957, and December 20, 1957, reinstating the sales application but excluding certain lots, including Lots Nos. 3804, 3805, 3806, and 3810-A. The Sociedad appealed this exclusion in D.A.N.R. Case No. 575-B.
Lots Nos. 3804, 3805, and 3806 were already covered by homestead patents issued to Montano Villarama, Leonardo T. Joson, and Felipe Sinaguinan, respectively, with corresponding certificates of title registered between 1951 and 1954. Crispulo Ceña also held a title under similar circumstances. The Sociedad claimed prior ownership and occupation of these lots, alleging the patents were fraudulently obtained while its sales application was under litigation.
On April 11, 1960, the Acting Secretary of Agriculture and Natural Resources remanded the case to the Director of Lands for further investigation, setting aside the effects of the December 20, 1957, order. The homestead patentees moved for reconsideration, arguing the lots were no longer public domain and thus beyond the Bureau’s jurisdiction.
On August 24, 1960, the Secretary issued an order finding that the Sociedad had acquired the lots before World War II and that the homestead applicants filed their applications in bad faith, knowing of the Sociedad’s claim. The Secretary declared the patent issuances “basically irregular and highly fraudulent” due to retroactive approvals intended to hasten the process. However, he acknowledged that the certificates of title had become irrevocable after one year from issuance, citing jurisprudence that homestead patents attain indefeasibility akin to titles under the Land Registration Act. Consequently, he excluded the lots from the Sociedad’s sales application but directed the Director of Lands to investigate officials responsible for the fraud.
Petitioners Joson (for himself and as vendee of Villarama’s lot) and Sinaguinan’s widow moved for reconsideration, which was denied on December 21, 1960. They then filed a petition for certiorari in the Court of First Instance of Nueva Ecija, seeking to annul the Secretary’s proceedings and orders, particularly the condemnatory findings of fraud. The trial court dismissed the petition on July 31, 1964, prompting this appeal.

ISSUE

Whether the Secretary of Agriculture and Natural Resources acted with grave abuse of discretion or in excess of jurisdiction in issuing the order of August 24, 1960, which included findings of fraud and irregularity in the issuance of the homestead patents, despite the lots being covered by certificates of title.

RULING

The Supreme Court affirmed the trial court’s dismissal of the petition. The Secretary’s findings of fraud and irregularity were within his administrative competence and authority, made in the exercise of his supervisory power over Bureau of Lands officials and for the purpose of directing an investigation into their conduct. The correctness of these findings is not reviewable by courts in a special civil action for certiorari.
On the due process issue, the Court held that petitioners were not denied due process. The Secretary’s order of April 11, 1960, had initially directed a formal investigation where petitioners could present their side. When petitioners objected, the Secretary set aside that order and proceeded without a formal investigation. The Court noted that petitioners could still participate in the investigation directed in the August 24, 1960, order. Moreover, the order had become functus oficio, as the Republic, through the Director of Lands, had already filed separate reversion cases in July 1962 (Court of First Instance of Nueva Ecija Case Nos. 3972 and 3976) seeking annulment of the patents and titles. These judicial proceedings would afford petitioners full opportunity to ventilate the issues in compliance with due process.
The decision appealed from was affirmed, with costs against petitioners-appellants.