G.R. No. L-30637; July 16, 1987
Lianga Bay Logging, Co., Inc., petitioner, vs. Hon. Manuel Lopez Enage, in his capacity as Presiding Judge of Branch II of the Court of First Instance of Agusan, and Ago Timber Corporation, respondents.

FACTS

Petitioner Lianga Bay Logging Co., Inc. and respondent Ago Timber Corporation are holders of adjacent timber concessions. A boundary dispute arose regarding their common limit, described in their licenses with reference to the Agusan-Surigao provincial boundary. The Director of Forestry conducted a survey and issued a decision fixing the boundary. Respondent Ago Timber appealed to the Department of Agriculture and Natural Resources (DANR), which reversed the Director’s ruling. Petitioner then appealed to the Office of the President, which affirmed the DANR Secretary’s decision. This administrative decision became final.
Subsequently, respondent Ago Timber filed a civil case for injunction and declaratory relief in the Court of First Instance of Agusan, seeking to nullify the administrative decisions and to establish a different boundary line. The trial court, presided by respondent Judge, assumed jurisdiction and issued a preliminary injunction against the enforcement of the final administrative ruling. Petitioner Lianga filed the instant petition for certiorari and prohibition, challenging the trial court’s jurisdiction.

ISSUE

Whether the Court of First Instance has jurisdiction to review, in a civil action, the final and executory decisions of the Director of Forestry, the Secretary of Agriculture and Natural Resources, and the Office of the President regarding the boundary of timber license areas.

RULING

No. The Supreme Court granted the petition, holding that the respondent judge acted without jurisdiction and with grave abuse of discretion. The Court reaffirmed the settled doctrine that findings of fact by administrative agencies, rendered within their statutory authority and after due hearing, are binding on the courts and will not be disturbed. Judicial review is limited to instances where the administrative official has acted without or in excess of jurisdiction, or with grave abuse of discretion tantamount to lack of jurisdiction. No such abuse was shown here.
The administrative proceedings, which culminated in a final decision from the Office of the President, conclusively determined the correct boundary line between the timber concessions. The civil action filed by respondent Ago Timber before the trial court was essentially an attempt to secure a re-determination of factual issues already settled in a final administrative adjudication. The trial court therefore had no cause of action before it and lacked jurisdiction to entertain the suit. The Court ordered the dismissal of the civil case and made permanent the restraining order against the trial court’s injunction.