GR 97028; (May, 1993) (Digest)
March 12, 2026GR 95755; (May, 1993) (Digest)
March 12, 2026G.R. No. L-25446; May 22, 1969
AMBROSIO SALUD, petitioner, vs. THE HON. EXECUTIVE SECRETARY TO THE PRESIDENT, ET AL., respondents.
FACTS
Petitioner Ambrosio Salud, claiming to be the successor-in-interest of the original applicant who paid the first installment for a parcel of land in the Sta. Cruz de Malabon Friar Land Estate in Quintana, Tanza, Cavite, sought recognition of his right from the Director of Lands. The Director of Lands decided in his favor, and this decision was confirmed by the Secretary of Agriculture and Natural Resources. However, upon appeal to the Executive Secretary, the decision was reversed, holding that the land was open for public sale to the highest bidder. Dissatisfied, Salud filed a special civil action for certiorari and mandamus in the Court of First Instance (CFI) of Manila. The lower court, through Judge Agustin P. Montesa, dismissed the suit on the ground that since the parcel of land was located in Tanza, Cavite, the CFI of Manila was without jurisdiction, characterizing the action as one “affecting title to, or for recovery of possession of real property” that should be commenced and tried in the province where the property lies.
ISSUE
Whether a petition for review of an administrative decision should be filed in the Court of First Instance of the province or city where the officer who rendered the decision holds office or where the real property subject of litigation is located.
RULING
The Supreme Court reversed the order of dismissal. It held that the CFI of Manila has jurisdiction to decide the matter on the merits. The Court reiterated the settled doctrine that the judicial tribunal where the executive official whose decision is sought to be assailed holds office has jurisdiction over such petitions for review, regardless of the location of the property involved. The Court cited several precedents, including Dizon v. Bayona, Sarabia v. The Secretary of Agriculture and Natural Resources, Suarez v. Reyes, Uichanco v. Secretary of Agriculture and Natural Resources, and Extensive Enterprises Corp. v. Sarbro & Co., Inc., where petitions for certiorari challenging decisions of the Secretary of Agriculture and Natural Resources or the Executive Secretary concerning lands or concessions located in various provinces were properly filed and entertained in the CFI of Manila or Rizal. The case was remanded to the lower court to be determined on its merits.
