G.R. No. L-21167; March 31, 1966
PRIMO GANITANO, petitioner-appellant, vs. HON. SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, ET AL., respondents-appellees.

FACTS

In 1955, Corazon B. Cabanos filed an application for a free patent over a parcel of land in Dingras, Ilocos Norte with the Bureau of Lands. Primo Ganitano opposed the application. On September 24, 1959, the Chief of Region No. 1 of the Bureau of Lands, acting under the authority of the Director of Lands, rendered a decision dismissing Ganitano’s opposition and giving due course to Cabanos’s application. Ganitano appealed to the Secretary of Agriculture and Natural Resources. On November 16, 1959, the Secretary, through his Undersecretary, affirmed the Bureau of Lands’ decision, finding that Cabanos had established a better right by virtue of her application and actual occupation and cultivation of the land. Ganitano’s motion for reconsideration was denied. On September 1, 1960, Ganitano filed a petition for certiorari with the Court of First Instance of Ilocos Norte, seeking annulment of the Secretary’s decision on the ground of abuse of discretion or lack of jurisdiction. The lower court dismissed the petition on October 29, 1962. Ganitano appealed, contending that the lower court erred in dismissing the petition merely based on the administrative findings and should have required the production and re-evaluation of all evidence presented during the administrative proceedings.

ISSUE

Whether the Court of First Instance (the court a quo) erred in dismissing the petition for certiorari without requiring the production and conducting a re-evaluation of the evidence presented in the administrative proceedings before the Director of Lands and the Secretary of Agriculture and Natural Resources.

RULING

The Supreme Court affirmed the decision of the lower court, dismissing Ganitano’s appeal. The Court held that the appellant’s posture was untenable. Under Commonwealth Act No. 141 (Public Land Act), the Secretary of Agriculture and Natural Resources, through the Director of Lands, has direct executive control over the disposition of public lands, and the Director’s decision on questions of fact is conclusive when approved by the Secretary. The Court ruled that it is beyond the competence and jurisdiction of the courts to substitute their judgment for that of these administrative officials on factual matters, as they are in a better position to consider and weigh the evidence. The well-settled doctrine is that courts will not interfere with purely administrative matters addressed to the sound discretion of government agencies unless there is a clear showing of arbitrary action, grave abuse of discretion, or a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. In this case, no such abuse was claimed; Ganitano merely sought a re-evaluation of the evidence, which is not permissible. The findings of administrative officials on public land matters are final and conclusive, subject only to the stated limitations.