GR 45314; (December, 1936) (Digest)
G.R. No. 45314. December 29, 1936.
W. F. STEVENSON & CO., LTD., petitioner, vs. EULOGIO RODRIGUEZ, Secretary of Agriculture and Commerce, and JOSE P. DANS, Director of Lands, respondents.
FACTS
Petitioner W.F. Stevenson & Co., Ltd., claiming absolute ownership over a parcel of land in Camarines Sur by virtue of Spanish-era possessory information and composition titles, filed a protest with the Bureau of Lands against several homestead applications covering portions of said land. The petitioner argued the Director of Lands had no jurisdiction because the land was private property. After an investigation, the Director of Lands found that the petitioner was not in material possession of the land and had not paid land taxes since 1901, whereas the homestead applicants were in possession and had made improvements. The Director dismissed the protest, a decision affirmed by the Secretary of Agriculture and Commerce.
ISSUE
Whether the Director of Lands had jurisdiction to conduct an investigation and decide on the homestead applications over land claimed to be private property under Spanish titles.
RULING
Yes. The Supreme Court upheld the jurisdiction of the Director of Lands. Under Section 4 of Act No. 2874 (Public Land Act), the Director is expressly authorized to conduct investigations to determine if lands applied for as homesteads are part of the public domain. The investigation’s factual finding that the petitioner was not in possession of the land justified the Director’s exercise of jurisdiction. The Court emphasized that the administrative decisions on the validity of titles were not final or indisputable. Furthermore, the extraordinary writ of certiorari was not proper because the petitioner had a plain, speedy, and adequate remedy by filing an ordinary civil action in the Court of First Instance to enforce its claimed ownership rights. The petition was denied.
AI Generated by Armztrong.