G.R. No. L-17328; March 30, 1963
CONRADO B. UICHANCO, petitioner-appellee, vs. THE HONORABLE SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, ET AL., respondents-appellants.

FACTS

Conrado B. Uichanco filed a sales application for public land, which was protested. The Director of Lands, after investigation, cancelled Uichanco’s application. Uichanco filed a motion for reinvestigation, alleging bias by the investigating lands inspector. The Director of Lands suspended his decision and ordered a reinvestigation by another investigator. Before this reinvestigation commenced, the Secretary of Agriculture and Natural Resources received an indorsement from the Office of the Executive Secretary, directing action on a separate protest letter against Uichanco. Acting on this, the Secretary created a committee to investigate, conducted hearings where Uichanco participated with counsel, and after ocular inspection, rendered a decision reinstating Uichanco’s application but excluding portions occupied by protestants.
Uichanco moved for reconsideration, arguing for the first time that the Secretary lacked jurisdiction because no appeal had been taken from the Director of Lands’ decision. Upon denial, Uichanco filed a petition for certiorari with the Court of First Instance of Manila. The lower court nullified the Secretary’s decision, ruling it was issued without jurisdiction and with grave abuse of discretion. The Secretary, through the Solicitor General, appealed.

ISSUE

Whether the Secretary of Agriculture and Natural Resources acted without jurisdiction in directly deciding the land conflict without a prior appeal from the decision of the Director of Lands.

RULING

The Supreme Court reversed the lower court’s decision, upholding the Secretary’s jurisdiction. The legal logic rests on the Secretary’s statutory powers of control and supervision under Section 79(C) of the Revised Administrative Code, which explicitly grants the Department Head the power to “repeal or modify the decisions of the chief of said bureaus or offices when advisable in the public interest.” This power is direct and inherent, not contingent upon the filing of a formal appeal by a party. While Lands Administrative Order No. 6 outlines a procedure for appeals, it does not prohibit the Secretary from exercising his supervisory authority sua sponte or upon a higher directive, as in this case where the matter was referred by the Office of the President. The Court emphasized that the rules of procedure are for administrative convenience and do not curtail the Secretary’s plenary power of control.
Furthermore, Uichanco’s active participation in the proceedings before the Secretary, including his requests for expedited resolution, constituted voluntary submission to its jurisdiction, estopping him from later challenging it. The Court also noted no violation of Uichanco’s substantive rights, as he was assisted by counsel and received a more favorable ruling from the Secretary than from the Director of Lands. Therefore, the Secretary acted within his jurisdiction and authority.