G.R. No. 42782 and G.R. No. 47936, September 29, 1989
FIGURADO O. PLAZA, petitioner, vs. HON. JUAN C. TUVERA, HON. JOSE J. LEIDO JR., HON. RAMON N. CASANOVA, and ERNESTO C. REYES, respondents. ( G.R. No. 42782 ) and FIGURADO O. PLAZA, petitioner, vs. ERNESTO C. REYES and HON. COURT OF APPEALS, respondents. (G.R. No. 47936)

FACTS

Petitioner Figurado O. Plaza purchased a 900-square-meter parcel of land from Luis Peggy in September 1966. However, the actual occupant, private respondent Ernesto C. Reyes, had already filed a Miscellaneous Sales Application for the same land with the Bureau of Lands earlier that same month. In November 1966, Plaza filed an accion publiciana (Civil Case No. 1128) against Reyes before the Court of First Instance of Agusan Del Norte to recover possession. The trial court ruled in Plaza’s favor in 1973, declaring Reyes a mere lessee and ordering him to vacate and pay damages.
Concurrently, administrative proceedings were ongoing regarding Reyes’s sales application. The Bureau of Lands officials initially recognized Plaza’s preferential right as Reyes’s alleged landlord. However, on appeal, the Office of the President reversed this in February 1975, finding Reyes entitled to purchase the land as a bona fide occupant. Meanwhile, Reyes appealed the trial court’s civil decision to the Court of Appeals. The appellate court, deferring to the final and executory presidential decision, dismissed Plaza’s civil case as moot and academic in 1977.

ISSUE

The primary legal question is whether the Office of the President, in exercising its executive authority over public land disposition, may issue a decision that effectively nullifies or renders moot a prior judicial decision from a court of first instance in an action for recovery of possession involving the same parcel of public land.

RULING

The Supreme Court dismissed both of Plaza’s petitions, upholding the authority of the Office of the President. The Court clarified that the land in dispute is unequivocally public land. Under Commonwealth Act No. 141 , the administration and disposition of lands of the public domain is an executive function, vested in the Director of Lands subject to the control of the Secretary of Agriculture and Natural Resources and, ultimately, the President. The Office of the President, through the Executive Secretary, possesses the full authority to review, affirm, reverse, or modify decisions of the Secretary concerning public land grants.
Consequently, the judicial decision in the accion publiciana did not bind the executive branch in the exercise of this distinct administrative prerogative. The Court emphasized that the disposition of public land is not a judicial function. Furthermore, the administrative case was instituted ahead of the civil suit. Plaza’s recourse to the courts was premature, as he failed to exhaust administrative remedies before filing his civil action. Therefore, the Court of Appeals correctly deferred to the final administrative decision, which had settled the issue of who had the right to purchase the land from the government, rendering the civil case for possession academic.