G.R. No. L-21275; July 31, 1967
ZAMBOANGA GENERAL UTILITIES, INC., petitioner-appellant, vs. THE HON. SECRETARY OF AGRICULTURE AND NATURAL RESOURCES; THE DIRECTOR OF LANDS and GOODRICH INTERNATIONAL RUBBER COMPANY, INC., respondents-appellees.

FACTS

Zamboanga General Utilities, Inc. (petitioner) filed a protest with the District Land Office in Zamboanga City against Goodrich International Rubber Company, Inc. (respondent) for forcible occupation and encroachment on public land the petitioner had applied for, occupied, and improved. The Director of Lands rendered a decision on June 27, 1958, awarding portions of the contested lots to both parties. The petitioner appealed to the Secretary of Agriculture and Natural Resources, which denied the appeal on February 26, 1959. After the Supreme Court dismissed the petitioner’s initial certiorari petition without prejudice, the petitioner filed a petition for certiorari with the Court of First Instance (CFI) of Basilan City on June 22, 1960, against the Secretary, the Director of Lands, and Goodrich. The respondents filed their answers. The petitioner later filed a petition for a preliminary injunction, which was granted but subsequently dissolved upon Goodrich’s motion and filing of a counterbond. On January 14, 1963, the respondents filed a joint motion to dismiss the certiorari petition, arguing the CFI of Basilan City lacked jurisdiction to review the decisions of the Secretary and Director of Lands under Section 44(h) of the Judiciary Act of 1948, citing the Samar Mining case. The lower court granted the motion and dismissed the petition on March 11, 1963. The petitioner appealed.

ISSUE

Whether the Court of First Instance of Basilan City has jurisdiction to review, via a writ of certiorari, the decisions of the Secretary of Agriculture and Natural Resources and the Director of Lands.

RULING

Yes. The Supreme Court set aside the order of dismissal and remanded the case to the lower court for further proceedings. The Court held that the CFI of Basilan City has jurisdiction over the petition for certiorari. It cited the precedent in Gayacao vs. Executive Secretary, which distinguished cases involving petitions for injunction to control actions of courts or officers outside the court’s territorial jurisdiction from cases, like the present one, where the sole issue is the legal correctness of an administrative decision. The power of judicial review of administrative decisions is not confined to the courts of first instance where the offices of the respondents are maintained but extends to courts where the plaintiff resides and where the questioned decisions are being enforced, to prevent hardship and denial of access to courts. The Court noted that the preliminary injunction issued had already been dissolved, leaving the main action as one for certiorari alone, and the jurisdiction to issue that injunction was no longer in question as it was not challenged by the respondent officials on jurisdictional grounds.