G.R. No. 157812. November 22, 2005.
RODOLFO SANTOS, Petitioner, vs. RONALD C. MANALILI as Heir or Representative of Deceased Defendants NOLI BELEN C. MANALILI and REYNALDO MANALILI & BOARD OF LIQUIDATORS, Respondents.

FACTS

The case involves a parcel of land formerly part of the Furukawa Plantation in Davao City, administered by the respondent Board of Liquidators (BOL). Reynaldo Manalili, predecessor of respondent Ronald Manalili, filed an application to purchase the land in 1970, supported by an Occupant’s Affidavit. The BOL processed his application, required payment, and eventually issued a Certification of Full Payment. In 1981, after a nine-year lapse, petitioner Rodolfo Santos filed a protest, claiming prior occupancy and acquisition of rights from a previous occupant. The BOL’s Alien Property Unit investigated and found Santos was not an actual occupant but had merely hired others to cultivate the land to simulate possession. The BOL dismissed Santos’s protest, approved the sale to Manalili, and a Deed of Absolute Sale was issued, leading to the issuance of a Transfer Certificate of Title in Manalili’s name in 1982.
Santos filed a complaint for Reconveyance, Damages, and/or Annulment of Title. The trial court dismissed his complaint, a decision affirmed by the Court of Appeals. Santos appealed to the Supreme Court, arguing he had a better right of possession and that the sale to Manalili was fraudulent, alleging the BOL’s investigation was flawed.

ISSUE

Whether the Court of Appeals erred in upholding the validity of the sale to the Manalilis and in affirming that the Manalilis had a better right of possession over the disputed land.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court upheld the factual findings of the BOL and the lower courts, emphasizing the principle that factual determinations of administrative agencies, when supported by substantial evidence, are accorded great respect and finality. The BOL’s investigation, which concluded that Santos was not an actual occupant and that his protest was intended to disturb the lawful sale, was based on substantial evidence. The Court noted that the sale underwent regular administrative procedures, culminating in approval by the Office of the President, giving rise to the presumption of regularity in the performance of official duty.
The legal logic rests on the superiority of the Manalilis’ claim derived from a valid administrative sale perfected prior to Santos’s protest. Possession, as a fact, was conclusively determined by the BOL in favor of Manalili based on his timely application and supporting affidavit. Santos’s belated claim, unsupported by convincing evidence of prior and continuous possession, could not overcome the validity of the perfected sale. The Court found no fraud, as the BOL duly investigated Santos’s protest before proceeding. Thus, the Torrens title issued to Manalili must be upheld, and Santos’s action for reconveyance or annulment necessarily fails.