G.R. No. L-4851 July 31, 1953
ELOY MIGUEL, ET AL., plaintiffs-appellants, vs. ANACLETA M. VDA. DE REYES, ET AL., defendants-appellees.

FACTS

On February 17, 1951, Eloy Miguel and his son Demetrio Miguel filed an action in the Court of First Instance of Isabela against Anacleta M. Vda. de Reyes, the Director of Lands, and the Register of Deeds. Eloy Miguel alleged he filed a homestead application for a nine-hectare parcel of public land in Angadanan, Isabela, on March 10, 1932. Demetrio Miguel claimed he declared for taxation and possessed a fourteen-hectare parcel in the same municipality since 1932. In January 1950, plaintiffs learned that defendant Anacleta M. Vda. de Reyes had included both parcels in a sales application with the Bureau of Lands. Plaintiffs filed a protest with the Bureau on February 16, 1950. The Director of Lands ordered an investigation, with a hearing set for February 10, 1951. However, pending the hearing, plaintiffs were informed on January 30 or 31, 1951, that defendant Anacleta M. Vda. de Reyes had been issued Sales Patent No. B-522 by the Director of Lands on January 10, 1951, and Original Certificate of Title No. T-1433 by the Register of Deeds on January 22, 1951, allegedly through “fraudulent machinations and false representations.” Plaintiffs prayed for the annulment of the sales patent, cancellation of the title, and damages. Defendants asserted compliance with the Public Land Law and moved to dismiss, arguing plaintiffs had no right to sue and the complaint stated no cause of action. The trial court dismissed the complaint, prompting this appeal.

ISSUE

Whether or not the plaintiffs can maintain this action in court, having failed to exhaust their administrative remedies.

RULING

No. The Supreme Court affirmed the order of dismissal. The complaint contained no clear averment that the lands were private property; instead, it indicated they were public lands, the disposition of which is vested in the Director of Lands, subject to appeal to the Secretary of Agriculture and Commerce. Plaintiffs, aggrieved by the Director of Lands’ action, did not appeal to the Secretary of Agriculture and Commerce. It did not even appear that they pursued their protest to its conclusion within the Bureau of Lands itself. Having failed to exhaust their administrative remedies, plaintiffs could not seek relief in the courts of justice. The Court brushed aside the appellants’ procedural contention regarding the motion to dismiss, finding it without basis.