G.R. No. 38387 ; January 29, 1990
HILDA WALSTROM, petitioner-appellant, vs. FERNANDO MAPA, JR., VICTORINO A. MAPA, MARIA C.M. DE GOCO, FERNANDO MAPA, III, MARIO L. MAPA, and THE REGISTER OF DEEDS OF THE PROVINCE OF BENGUET, respondents-appellees.

FACTS

The case involves a dispute over a parcel of land in La Trinidad, Benguet. Petitioner Hilda Walstrom, representing the heirs of Cacao Dianson, claimed ownership based on a Free Patent Application (FPA) filed in 1933, which resulted in the issuance of Original Certificate of Title No. 1217. The private respondents, heirs of Josefa Abaya Mapa, based their claim on a Miscellaneous Sales Application awarded in 1934. The core conflict arose when Dianson protested Mapa’s construction of a structure on a portion of the land in 1956, leading to a Bureau of Lands investigation. The investigator’s report highlighted conflicting claims and noted the Mapa property had not been formally surveyed, while Dianson’s land had been. Despite the unresolved administrative proceedings, Walstrom filed a civil action in the Court of First Instance seeking annulment of the respondents’ title and reconveyance of the property.
The trial court dismissed the complaint before trial on the ground of non-exhaustion of administrative remedies. It ruled that Walstrom’s “Petition for Relief” was still pending with the Secretary of Agriculture and Natural Resources, who could reconsider the matter. Furthermore, citing Kabayan vs. Republic, the court held that an action for annulment of a title issued pursuant to a patent must be initiated by the Director of Lands or with his prior authority and consent, which Walstrom failed to secure. The dismissal was based on lack of cause of action, not lack of jurisdiction.

ISSUE

Whether the trial court correctly dismissed the complaint for failure to exhaust administrative remedies and for lack of cause of action due to the absence of consent from the Director of Lands to file the suit.

RULING

Yes, the Supreme Court affirmed the dismissal. The doctrine of exhaustion of administrative remedies is fundamental. Walstrom’s administrative “Petition for Relief” was still pending, and the Secretary of Agriculture and Natural Resources retained the power to reconsider the land award. Judicial intervention was premature until this administrative process was completed. Furthermore, the Court upheld the applicability of Kabayan vs. Republic, which mandates that a suit to annul a title issued under a public land patent must be filed by the Director of Lands or with his prior consent. This rule aims to prevent indiscriminate suits that could undermine the Torrens system and is based on the state’s paramount interest in public land disposition. Walstrom’s failure to allege or secure such consent rendered her complaint without a valid cause of action.
The Court clarified that the petitioner’s proper recourse, should her administrative petition succeed, would be an action for reconveyance based on an implied or constructive trust, not a direct annulment of title. In such an action, the Torrens decree is respected as incontrovertible, and the remedy is to transfer the property to its rightful owner. However, this action prescribes in ten years from the issuance of the title. The trial court’s order was found free of reversible error, as it correctly applied the rules on exhaustion of administrative remedies and the requisite authority for filing suit concerning public land patents.