GR L 2326; (May, 1949) (Digest)
G.R. No. L-2326; May 31, 1949
FERNANDO ALEJO, ET AL. vs. MARIANO GARCHITORENA, ET AL.
FACTS
Petitioners Fernando Alejo, et al., filed a petition for certiorari in the Court of First Instance of Nueva Ecija to review and set aside the decision of the Director of Lands and the confirmatory decision of the Secretary of Agriculture and Natural Resources regarding a land dispute between homesteaders. Petitioners alleged that the decisions were rendered with grave abuse of discretion, in excess of jurisdiction, based on false assumptions from a prior investigation of which no record exists and of which they were not notified, and were the consequence of fraud and misrepresentation by the opposing party. Without receiving any evidence and solely upon the Solicitor General’s motion, the lower court dismissed the petition, ruling that the decisions of the administrative officials were conclusive upon the courts.
ISSUE
Whether the lower court erred in dismissing the petition for certiorari without giving petitioners an opportunity to prove their allegations of fraud, grave abuse of discretion, and lack of factual basis or proper hearing, which would justify judicial review of the administrative decisions.
RULING
Yes. The Supreme Court reversed the lower court’s order of dismissal and remanded the case for further proceedings. While the decision of the Director of Lands, when approved by the department head, is conclusive as to questions of fact under Section 4 of Commonwealth Act No. 141 , it is subject to judicial review if rendered in consequence of fraud, imposition, or mistake, other than error of judgment in estimating evidence. Petitioners’ allegations—that the decisions were based on fictitious facts, inferences from an investigation without record or notice, and contrary to findings from hearings where they were parties—if proven, would justify judicial intervention. The lower court’s dismissal without allowing petitioners to present evidence was a clear judicial error. The Court also noted that the plea of laches or unreasonable delay could not be decided without proof or admission of the circumstances.
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