G.R. No. L-18587. April 23, 1963.
APOLINARIO VALERIO, plaintiff-appellee, vs. HON. SECRETARY OF AGRICULTURE & NATURAL RESOURCES, ET AL., defendants, LUCERO DE GUZMAN, defendant-appellant.
FACTS
Apolinario Valerio and Lucero de Guzman filed conflicting applications to purchase the same residential lot within a government subdivision for resale to bona fide occupants. The Director of Lands, after a hearing, awarded the lot to Valerio. De Guzman appealed to the Secretary of Agriculture and Natural Resources, who reversed the award in favor of de Guzman on January 14, 1953. Valerio’s counsel received a copy of this adverse decision on March 9, 1953, but Valerio filed a motion for reconsideration only on October 30, 1953, well beyond the 30-day reglementary period. The Secretary denied the motion as belated, rendering his decision final. Valerio then filed a complaint in the Court of First Instance of Manila to annul the Secretary’s decision, asserting his preferential right as the actual occupant.
ISSUE
Whether the Court of First Instance validly annulled the final and executory administrative decision of the Secretary of Agriculture and Natural Resources.
RULING
No. The Supreme Court reversed the lower court’s decision and reinstated the award to Lucero de Guzman. The legal logic is anchored on the doctrine of finality of administrative decisions and the binding effect of notice to counsel of record. An administrative decision, once final and executory, becomes immutable and unalterable. The Secretary’s decision became final when Valerio failed to file a motion for reconsideration within the mandatory 30-day period from notice. Notice to his counsel of record, Atty. Dario Aquino, constituted valid notice to Valerio himself. The subsequent withdrawal of his counsel without client consent did not invalidate this notice or toll the reglementary period. The lower court therefore acted without jurisdiction in reviewing and annulling a decision that had already attained finality. On the substantive merits, which the Court also examined, the evidence supported the Secretary’s finding that de Guzman was the prior bona fide occupant, having paid rentals and introduced improvements before Valerio’s entry, which was done with knowledge of de Guzman’s claim. Valerio’s possession was thus not in good faith under Commonwealth Act No. 539.