G.R. No. L-14591; April 25, 1962
PINDAÑGAN AGRICULTURAL COMPANY, INC., plaintiff-appellee, vs. JOSE P. DANS, as Director of the Bureau of Lands; PLACIDO L. MAPA, as Secretary of Agriculture and Natural Resources; PEDRO U. ASENSI, as District Land Officer; EMERTERIO DE LOS SANTOS, ET AL., defendants-appellants.

FACTS

The land in question, over 491 hectares in Alcala, Pangasinan, originally belonged to Cristina Gonzales. After a mortgage foreclosure, title passed to the Government in 1923. Cristina, who had married a Swiss citizen, formed a corporation to apply for a lease, but this was opposed by 93 tenant families who had worked the land. After protracted litigation, the Supreme Court in a prior case annulled a subsequent repurchase by Cristina, ruling she was disqualified as an alien. The tenant families then formed the Pindañgan Agricultural Company (the Company), which filed a lease application (No. 109) and later a sales application for the land. However, based on a 1948 field investigation which found that nearly 200 original tenants and occupants desired to purchase their individual holdings, the land officials rejected the Company’s applications and instead recommended subdivision and sale to the occupants.
The Company filed an action in the Court of First Instance of Pangasinan, which ruled in its favor. The trial court nullified the officials’ resolutions, ordered them to give due course to the Company’s applications, and awarded damages. The land officials and the occupant-defendants appealed.

ISSUE

Whether the trial court erred in reversing the administrative decisions of the Director of Lands and the Secretary of Agriculture and Natural Resources, which rejected the Pindañgan Agricultural Company’s lease and sales applications in favor of subdivision and sale to the individual occupant-tenants.

RULING

Yes, the trial court erred. The Supreme Court reversed its decision and dismissed the Company’s petition. The Court emphasized the well-established doctrine that findings of fact by administrative agencies, when supported by substantial evidence, are binding and conclusive upon the courts. The field investigation conducted in 1948 provided a substantial factual basis for the land officials’ decision. The investigation revealed that the original tenants and occupants, many of whom were not members of the Company or derived no benefit from it, had been in continuous possession since the early 1900s and desired to own the land they actually occupied. The administrative decision to subdivide and sell to these individual occupants was a valid exercise of discretion aimed at implementing land distribution policies.
Furthermore, the action was essentially one for mandamus. For such a writ to issue, the petitioner must demonstrate a clear legal right to the performance of the act and a corresponding ministerial duty on the part of the official to perform it. The Company failed to establish such a clear right. The approval of public land applications is discretionary, not ministerial, and the courts cannot compel a particular exercise of that discretion. The Supreme Court found no proof of bad faith or abuse of discretion by the land officials. Therefore, the trial court had no valid ground to substitute its judgment for that of the administrative authorities. The resolutions of the Director of Lands and the Secretary were reinstated.