GR 76761; (January, 1989) (Digest)
G.R. No. 76761 January 9, 1989
THE HON. ASST. EXECUTIVE SECRETARY FOR LEGAL AFFAIRS OF THE OFFICE OF THE PRESIDENT OF THE PHILIPPINES, THE BOARD OF LIQUIDATORS, AND THE DIRECTOR OF LANDS, petitioners, vs. THE HON. COURT OF APPEALS AND BASILIO MENDOZA, respondents.
FACTS
The controversy involves a parcel of land, originally designated as Home Lot No. 336 (later Lot No. 355), with an area of 1,500 square meters in the Marbel Settlement District, Cotabato. In 1948, Jesus Larrabaster applied for this lot, and his application was granted in 1950. In 1956, Larrabaster assigned his rights to Jose Peña. Over time, due to accretion from a surrounding creek, the actual area of the lot increased to 3,616.93 square meters. Peña requested the Board of Liquidators (BOL) to adjust the awarded area to reflect this increase, but the BOL denied his request, proposing instead to subdivide the enlarged area into three separate lots for allocation to different parties, including private respondent Basilio Mendoza.
Peña appealed to the Office of the President. In a Decision dated May 13, 1969, the Office of the President ruled in Peña’s favor, maintaining the award of the original Lot No. 355 to him and holding that the benefits of accretion accrued to him as the awardee, pursuant to Article 457 of the Civil Code. Mendoza, who had been allocated a portion of the subdivided lot by the Bureau of Lands, filed a protest. The Office of the President, in a subsequent letter-decision dated September 28, 1971, affirmed its earlier ruling. Mendoza then filed a petition for certiorari with the Court of First Instance, which was dismissed. On appeal, the Court of Appeals reversed the trial court, setting aside the administrative decisions.
ISSUE
Whether the Court of Appeals erred in setting aside the administrative decisions of the Office of the President which awarded the disputed lot, including its accretions, to Jose Peña.
RULING
Yes, the Supreme Court reversed the Court of Appeals and reinstated the trial court’s decision. The legal logic is anchored on the nature of the award and the law on accretion. The original grant of the 1,500-square-meter lot to Larrabaster was a perfected award, vesting in him a vested right to the property, which he validly assigned to Peña. The Government retained only the naked title pending the issuance of a final patent. Consequently, under Article 457 of the Civil Code, accretions to a property belong to the riparian owner. Since the award to Larrabaster/Peña was perfected, Peña, as the beneficial owner, was entitled to all additions to the land formed by accretion. The land was thus no longer public land subject to further disposition by the Government. Mendoza’s subsequent sales application over a portion was therefore without legal effect.
Furthermore, the Supreme Court emphasized the settled doctrine of respect for administrative findings. The decisions of the Office of the President were supported by substantial evidence and were rendered within its executive jurisdiction. There was no proof of gross abuse of discretion, fraud, or error of law that would justify judicial overturning. The Court of Appeals improperly substituted its judgment for that of the administrative agency. To reopen the case would perpetuate a litigation already pending for approximately nineteen years.