G.R. No. 83907 . September 13, 1989.
NAPOLEON GEGARE, petitioner, vs. HON. COURT OF APPEALS (ELEVENTH DIVISION) AND ARMIE ELMA, respondents.

FACTS

The controversy involves Lot 5989, originally titled to Paulino Elma. A reversion case filed by the Republic resulted in the cancellation of Elma’s title, with the lot reverting to the public domain. The court decision, affirmed by the Supreme Court, gave preferential right to the actual occupant, Napoleon Gegare. Both Gegare and Armie Elma, an heir of Paulino Elma, filed applications with the Board of Liquidators. Initially, the Board favored Gegare. However, after investigations and protests, the Board ultimately passed Resolution No. 272, Series of 1981, dividing the lot equally between Gegare and Elma. This administrative resolution was affirmed by the Office of the President.
Gegare filed a civil case in the Regional Trial Court seeking to annul the Board’s partition resolutions and Elma’s resulting title. Elma moved to dismiss the complaint on several grounds, including lack of jurisdiction. The trial court initially granted the motion but later reconsidered and allowed the case to proceed. Elma then filed a petition for certiorari with the Court of Appeals, which granted the petition, declared the trial court’s orders null and void, and directed the dismissal of the civil case for lack of jurisdiction. Gegare’s motion for reconsideration was denied.

ISSUE

The primary issue is whether the Regional Trial Court had jurisdiction over Gegare’s action to annul the administrative resolutions of the Board of Liquidators partitioning the lot and the consequent title issued to Elma.

RULING

The Supreme Court dismissed the petition, affirming the Court of Appeals’ decision. The trial court correctly lacked jurisdiction over the subject matter of the complaint. The disposition of the lot, a public land, was an administrative function carried out by the Board of Liquidators under the authority of the President. The Board’s resolution partitioning the lot, which was subsequently affirmed by the Office of the President, constituted a final administrative action. Judicial review of such administrative decisions is limited to instances of lack or excess of jurisdiction or grave abuse of discretion, typically raised through a special civil action for certiorari under Rule 65 of the Rules of Court. Gegare’s ordinary civil action for annulment was an improper remedy to collaterally attack a final administrative determination. Furthermore, the real party-in-interest to question a land grant is the government, not a private individual like Gegare. The Court also noted that Gegare failed to comply with the mandatory conciliation requirement under P.D. No. 1508 (the Katarungang Pambarangay Law) before filing his court action, as the contending private parties were residents of the same barangay.