G.R. No. L-17197; September 29, 1962
MANUEL S. GALVEZ, ET AL., petitioners, vs. VALENTINA TAGLE VDA. DE KANGLEON, ET AL., respondents.

FACTS

In December 1947, Ruperto K. Kangleon applied with the Rural Progress Administration (RPA) to purchase a homesite lot in the La Faja Del Mar Estate. The RPA adjudicated Lot No. 7 to him in August 1950, sending a sales memorandum. Kangleon did not reply to this notice nor pay the required first installment. Deeming this as abandonment, the RPA manager, without prior notice to Kangleon, sold the same lot to Venancio Presingular and companions on December 29, 1950. This sale occurred after Executive Order No. 376 (dated November 28, 1950) had abolished the RPA, transferring its functions to the Bureau of Lands. Presingular later sold his rights to spouses Manuel and Ester Galvez. Kangleon protested to the Director of Lands, who voided the December 1950 RPA sale but upheld a subsequent October 1951 agreement to sell executed by the Director of Lands to Presingular. The Secretary of Agriculture and Natural Resources, on appeal, upheld the RPA manager’s 1950 sale as a valid act of a de facto officer and gave Kangleon an option to purchase the lot from Galvez by reimbursing the P20,000 paid. Kangleon did not exercise this option.

ISSUE

Whether the Secretary of Agriculture and Natural Resources committed a grave abuse of discretion in upholding the sale of the lot to Presingular and, subsequently, to the Galvez spouses, thereby denying Kangleon’s claim.

RULING

The Supreme Court reversed the lower court and dismissed the respondents’ action. The legal logic centers on administrative finality and the absence of a perfected contract in favor of Kangleon. The findings of the Secretary of Agriculture and Natural Resources—that Kangleon failed to pay the installment, showed a lack of interest amounting to negligence, and thereby forfeited his preferential claim—are factual conclusions binding upon the courts. These findings can only be overturned upon a showing of arbitrariness or grave abuse of discretion, which was not present. The Court found sufficient justification for the sale to Presingular, who was in actual possession of the lot, aligning with the policy under Commonwealth Act No. 539 to give preference to occupants for homesite purposes. Kangleon, as Secretary of National Defense with other properties, did not have a superior claim under this policy. Furthermore, Republic Act No. 65, which grants purchase preferences to veterans, applies to agricultural lands, not homesites like the La Faja Del Mar Estate. Since no perfected contract of sale existed between Kangleon and the RPA, and the administrative officials acted within their discretion, the subsequent sales were valid. The Court deemed it unnecessary to address other ancillary issues raised by the petitioners.