G.R. No. L-49541-52164 March 28, 1980
ANTERO IGNACIO, petitioner, vs. THE HON. COURT OF APPEALS, LAURENDA BAUTISTA, HONORABLE EXECUTIVE SECRETARY, and HONORABLE SECRETARY OF AGRICULTURE and NATURAL RESOURCES, respondents; LAURENDA S. BAUTISTA, petitioner, vs. HON. EXECUTIVE SECRETARY, HON. SECRETARY OF AGRICULTURE AND NATURAL RESOURCES and ANTERO IGNACIO, respondents.

FACTS

The consolidated cases originated from a land dispute over parcels in Malita, Davao. The heirs of Fernandez Uguiz, represented by Antero Ignacio, protested the homestead and sales applications of Mariano and Anazaria Bautista (parents of Laurenda Bautista), claiming overlap with Uguiz’s earlier homestead patent. After a series of administrative decisions by the Bureau of Lands, the Director of Lands, and the Secretary of Agriculture and Natural Resources, the Office of the President, through Assistant Executive Secretary Ronaldo Zamora, rendered a decision on January 23, 1973, awarding the contested portions to the Uguiz heirs. Laurenda Bautista’s motion for reconsideration was denied.
Bautista then filed a petition for certiorari with the Court of First Instance of Davao to annul the Executive Secretary’s decision, alleging abuse of discretion. The trial court dismissed the petition, finding it defective in form and substance. It noted the petition failed to attach certified true copies of certain orders, omitted a specific decision, and did not state the factual findings sought to be reviewed. More critically, the court ruled the petition failed to allege specific facts showing grave abuse of discretion, constituting at most an error of judgment not correctible by certiorari. Bautista appealed to the Court of Appeals.

ISSUE

The primary issue is whether the Court of Appeals correctly resolved the appeal, which hinges on whether Bautista’s petition for certiorari before the trial court was sufficient to warrant judicial review of the administrative decision.

RULING

The Supreme Court affirmed the trial court’s dismissal. The legal logic centers on the limited scope of judicial review over final administrative decisions. For a petition for certiorari to prosper against an executive officer’s decision, it must specifically allege that the officer acted without or in excess of jurisdiction or with grave abuse of discretion. Grave abuse of discretion implies a capricious, arbitrary, or despotic exercise of power, amounting to a virtual refusal to perform a duty.
The Court held that Bautista’s petition was fatally defective. It did not allege with certainty any specific, patent act constituting grave abuse. Merely charging “abuse of discretion” without qualifying it as “grave” and without supporting factual allegations is insufficient. The administrative findings of fact by the Secretary of Agriculture and the Executive Secretary are conclusive upon the courts, absent a showing of fraud, imposition, or mistake other than error of judgment. Since Bautista failed to state enough facts to make a prima facie case for grave abuse, the trial court correctly dismissed the petition. The Court of Appeals’ subsequent certification of the appeal to the Supreme Court, recognizing the pure question of law involved, rendered Ignacio’s separate petition moot.