G.R. No. L-27811 November 17, 1967
LACSON-MAGALLANES CO., INC., plaintiff-appellant, vs. JOSE PAÑO, HON. JUAN PAJO, in his capacity as Executive Secretary, and HON. JUAN DE G. RODRIGUEZ, in his capacity as Secretary of Agriculture and Natural Resources, defendants-appellees.

FACTS

In 1932, Jose Magallanes was a permittee and occupant of a 1,103-hectare pasture land in Tamlangon, Bansalan, Davao. On January 9, 1953, he ceded his rights to a portion (392.7569 hectares) of this land to plaintiff Lacson-Magallanes Co., Inc. This portion was released from the forest zone and declared agricultural land on April 13, 1954. On January 26, 1955, Jose Paño and nineteen other claimants applied to purchase ninety hectares of the released area. On March 29, 1955, the plaintiff corporation filed its own sales application for the entire released area, which was protested by Paño and his companions, who claimed to be actual occupants of the part they applied for. The Director of Lands, after investigation, decided on July 31, 1956, in favor of the plaintiff corporation and dismissed the claim of Paño and his companions. The Secretary of Agriculture and Natural Resources, on appeal, affirmed this decision on July 5, 1957. The case was then elevated to the President of the Philippines. On June 25, 1958, Executive Secretary Juan Pajo, “[b]y authority of the President,” reversed the prior decisions. He directed that the controverted land be subdivided and allocated to the actual occupants (Paño and companions), without prejudice to the corporation’s right to reimbursement for survey costs. The plaintiff corporation filed a case in the Court of First Instance seeking to declare the Secretary of Agriculture’s decision as having full force and effect and the Executive Secretary’s decision as contrary to law. The lower court dismissed the plaintiff’s case, prompting this appeal.

ISSUE

May the Executive Secretary, acting by authority of the President, reverse a decision of the Director of Lands that had been affirmed by the Secretary of Agriculture and Natural Resources?

RULING

Yes. The Supreme Court affirmed the lower court’s judgment. The President’s constitutional duty to execute the law and his control over all executive departments imply the authority to review, confirm, modify, or reverse the actions of department secretaries. The standard practice of allowing appeals from decisions of the Secretary of Agriculture and Natural Resources to the Office of the President is recognized and is based on the President’s power of control. This power of control includes the power to alter or nullify a subordinate’s act and substitute his own judgment. The Executive Secretary, acting by authority of the President, exercises this power on behalf of the President. The Court held that such a decision by the Executive Secretary, unless disapproved by the President, is the act of the President and must be given full faith and credit. The constitutional provision making decisions of the Director of Lands conclusive on questions of fact when approved by the Secretary of Agriculture (Section 4, Commonwealth Act 141) does not limit the President’s power of control. Furthermore, the delegation of this power to the Executive Secretary is valid, as the President is not required to perform all executive functions personally.