GR 79684; (February, 1991) (Digest)
G.R. No. 79684; February 19, 1991
DIRECTOR OF LANDS and SECRETARY OF ENVIRONMENT AND NATURAL RESOURCES, petitioners, vs. THE COURT OF APPEALS and B.A. GONZALES SURVEYING CO., INC., respondents.
FACTS
The petitioners, the Director of Lands and the Secretary of Environment and Natural Resources, entered into two separate contracts with private respondent B.A. Gonzales Surveying Co., Inc. The first, in 1973, was for a public land subdivision mapping (PLSM) project in Valderama, Antique. The second, in 1974, was for a photo-cadastral mapping (PCADM) project in Numancia, Aklan. The Director of Lands subsequently cancelled both contracts due to the private respondent’s failure to commence the Numancia project and to complete the Valderama project despite extensions. The private respondent appealed both cancellation orders to the Secretary of Environment and Natural Resources, where the appeals remained pending.
While these appeals were unresolved, the Director of Lands conducted a public bidding for the cadastral survey of several municipalities, including Numancia and Valderama, and declared new winning bidders. The private respondent then filed a petition for prohibition and mandamus with the Court of Appeals, arguing that the Director of Lands acted without jurisdiction in awarding the projects to others while its appeals were pending. The Court of Appeals granted the petition and issued a permanent injunction against the awards.
ISSUE
Whether the Court of Appeals erred in enjoining the award of the cadastral survey projects to new contractors on the ground that it would pre-empt the pending administrative appeals regarding the private respondent’s cancelled mapping contracts.
RULING
Yes, the Court of Appeals committed reversible error. The Supreme Court granted the petition, annulled the appellate court’s decision, and lifted the injunction. The legal logic is anchored on the doctrine of primary administrative jurisdiction and the distinct nature of the contracts involved. The Court held that the cadastral survey projects and the graphical mapping (PLSM/PCADM) projects, while both ultimately serving land registration purposes, are technically different and serve different stages of the land titling process. A graphical survey cannot substitute for a numerical cadastral survey, which is a prerequisite for registration.
Crucially, the cancellation of the private respondent’s contracts had already become effective, notwithstanding the pending appeals. The act of bidding out new projects for a different type of survey did not constitute an adjudication of those appeals nor pre-empt the Secretary’s authority to resolve them. The private respondent’s proper recourse was to expedite its administrative appeals, not to seek judicial intervention to restrain an administrative function. The injunction improperly interfered with the Director of Lands’ prerogative to undertake necessary public surveys and violated the principle that courts should not prematurely interfere with ongoing administrative processes.