GR L 20051; (May, 1966) (Digest)

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⚖️ CASE INTELLIGENCE

📌 CORE DOCTRINE

“it was filed outside the 30-day reglementary period prescribed by Forestry Administrative Order No.”

💡 PLAIN ENGLISH SUMMARY

VERIFIED AI SNAPSHOT FOR ARMZTRONG.ORG

G.R. No. L-20051 May 30, 1966
ANTIQUE SAWMILLS, INC., petitioner and appellant, vs. AQUILES R. ZAYCO, ET AL., respondents and appellees.

FACTS

A public bidding was conducted for a forest area. The Director of Forestry awarded the bid to respondent Aquiles R. Zayco. The losing bidders, including petitioner Antique Sawmills, Inc., appealed to the Secretary of Agriculture and Natural Resources (Secretary), who affirmed the award. Upon a motion for reconsideration, the Secretary modified his order on July 14, 1955, awarding the area in equal portions to Zayco and Antique Sawmills. Zayco filed a motion for reconsideration against this order, which was denied. He then filed a second motion for reconsideration. On February 15, 1956, the Secretary denied this second motion, ruling it was filed outside the 30-day reglementary period prescribed by Forestry Administrative Order No. 6-2, and declared the July 14, 1955 order final and executory. Zayco appealed the February 15, 1956 order to the Office of the President. On August 27, 1956, the Executive Secretary rendered a decision sustaining Zayco’s appeal, reversing the Secretary’s July 14, 1955 order, and awarding the entire concession to Zayco, relaxing the reglementary period on grounds of equity and lack of legal basis for the modified award. Antique Sawmills filed a petition for certiorari with the Court of First Instance of Manila, which was dismissed, prompting this appeal.

ISSUE

Whether the Office of the President retains jurisdiction to review on appeal a decision of the Secretary of Agriculture and Natural Resources which has become final due to the lapse of the reglementary period for appeal.

RULING

No. The Supreme Court reversed the decision of the lower court. Compliance with the period provided by law or regulation for the perfection of an appeal is not merely mandatory but jurisdictional. The period fixed in the Forestry Administrative Order has the force and effect of law. Since Zayco failed to perfect his appeal within the reglementary period, the order of July 14, 1955 had become final and executory. Consequently, the Office of the President no longer had jurisdiction to review the case. Public policy demands finality to administrative proceedings. The award made under the Secretary’s order dated July 14, 1955 was declared valid, effective, and subsisting.

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