GR 146385; (August, 2006) (Digest)
G.R. No. 146385 , August 17, 2006
Estefanio Biasura, Petitioner, vs. Regional Trial Court, Branch 42, Dagupan City, Gregorio, Federico, Julio Vera, Respondents.
FACTS
The dispute involves Lot No. 20203 in San Fabian, Pangasinan. Private respondents, the Vera brothers, claimed ownership by accretion as riparian owners. Petitioner Estefanio Biasura also filed a protest, claiming ownership based on actual possession. The DENR Regional Executive Director initially ruled in favor of Biasura in 1990. Following a motion for reconsideration and further proceedings, the DENR Director reaffirmed this decision on May 31, 1991, declaring Biasura the absolute owner. Private respondents filed another motion for reconsideration, which was denied for being filed out of time. They subsequently filed a petition for certiorari with the Regional Trial Court (RTC) to annul the DENR orders.
The RTC granted the petition, setting aside the DENR decisions, canceling surveys in Biasura’s favor, and reopening the DENR proceedings. The court found the DENR’s 1990 order lacked factual support and that the 1991 decision denied due process. Biasura elevated the case to the Court of Appeals via a petition for certiorari under Rule 65. The appellate court affirmed the RTC decision in toto, prompting Biasura to file the present petition before the Supreme Court.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s decision which granted the petition for certiorari against the DENR Director’s orders.
RULING
The Supreme Court denied the petition, upholding the decisions of the lower courts. The Court clarified that a writ of certiorari under Rule 65 is proper not merely for errors of judgment, but when a tribunal acts without or in excess of jurisdiction or with grave abuse of discretion, and there is no plain, speedy, and adequate appeal. While administrative factual findings are generally respected, they may be reversed on certiorari if the agency grossly misappreciates evidence to a degree that constitutes arbitrariness.
In this case, the RTC correctly exercised certiorari jurisdiction. The DENR Director committed a jurisdictional error, not a mere error of judgment, by awarding Lot No. 20203 to Biasura based on evidence pertaining to an entirely different property. The tax declaration presented by Biasura did not refer to Lot No. 20203. Furthermore, evidence showed Biasura was in active military service until 1984, making his claim of continuous possession since 1970 improbable, especially as the lot was reportedly still under water during that period due to river accretion. This patent disconnect between the evidence and the award constituted grave abuse of discretion, justifying the RTC’s intervention via certiorari. The Court of Appeals therefore committed no error in its affirmance.