G.R. No. L-33646. January 28, 1975.
AMADO LACUESTA, petitioner, vs. A. MELENCIO HERRERA in her capacity as Presiding Judge of Branch XVII of the COURT OF FIRST INSTANCE OF MANILA, and HEIRS OF ROBERTO DOROMAL Represented by Florita Doromal, respondents.

FACTS

Petitioner Amado Lacuesta and the spouses Roberto and Florita Doromal were partners in developing a 125.5-hectare public fishpond. The Davao Court of First Instance, in a final 1963 judgment for specific performance and accounting, confirmed the partnership and Lacuesta’s right to a one-half share. However, the court declared itself without authority to order partition, as the fishpond remained public land under a government permit issued solely to Roberto Doromal. Consequently, Lacuesta initiated an administrative protest with the Philippine Fisheries Commission, seeking partition of the area.
The Fisheries Commissioner denied Lacuesta’s protest. On appeal, the Secretary of Agriculture and Natural Resources reversed the Commissioner. The Secretary’s 1968 decision, citing the Davao court’s findings and conducting an independent review, ruled that Lacuesta had equitable rights to one-half of the fishpond area and ordered its partition. This decision was affirmed by the Office of the President. Despite these final administrative rulings, the Doromal heirs filed a petition for injunction with the Court of First Instance of Manila, which then issued a preliminary injunction restraining the enforcement of the Secretary’s decision.

ISSUE

Whether the respondent court committed grave abuse of discretion in issuing a preliminary injunction to restrain the enforcement of a final and executory administrative decision.

RULING

Yes. The Supreme Court granted the petition for certiorari and annulled the injunction. The Court reiterated the settled doctrine of non-interference by the judiciary in administrative matters. Where an administrative decision, as rendered by the Secretary of Agriculture and Natural Resources and affirmed by the Office of the President, is supported by substantial evidence and is not tainted by fraud, collusion, arbitrariness, illegality, imposition, or mistake, it is entitled to great weight and finality. The respondent court’ issuance of an injunction constituted an unwarranted judicial intrusion into the executive domain. The administrative agencies had acted within their jurisdiction, thoroughly evaluated the evidence—including the prior judicial findings of partnership—and reached a reasoned conclusion. Therefore, the lower court’s order restraining the execution of that final decision was a grave abuse of discretion amounting to lack or excess of jurisdiction. The Court found it unnecessary to resolve the ancillary issue regarding the extraterritorial enforcement of the injunction.