Facts:

On February 11, 1946, Eusebio Constantino filed a homestead application (No. D-366; E-D-385) for a 24-hectare parcel of land in Barrio Nangalisan, Solana, Cagayan. This application was a reconstitution of a prior application from 1924 that was lost during World War II. The original application gained traction as H.A. No. 401426, with a survey conducted in 1930. However, doubts arose regarding the exact area of the land when the 1946 application was submitted, prompting a relocation survey. Several individuals, notably Marcos Abig, Honorata Cagumbay, and Lino Pagulayan, claimed different portions of the same land during this survey. Evidence presented in support of their claims included testimonies from each party about their respective possession since 1921, asserting that they had cleared and cultivated the land as their own.

The Bureau of Lands conducted an investigation into these claims, where Constantino provided support through testimonies from witnesses, while Abig, Cagum

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Facts:

Background of the Homestead Application

• On February 11, 1946, Eusebio Constantino reconstituted his homestead application (Nos. D-366; E-D-385) for a parcel of land of about 24 hectares located in Barrio Nangalisan, Solana, Cagayan.
• The application was a reconstitution of an earlier 1924 application whose records were lost during the last war.
• The land had been originally given due course under Homestead Application No. 401426 and was surveyed in 1930 by a Bureau of Lands surveyor.
• Doubts regarding the area of the land necessitated a relocation survey conducted by another surveyor from the Bureau of Lands.

Emergence of Adverse Claims

• During the relocation survey, three parties—Marcos Abig, Honorata Cagumbay, and Lino Pagulayan—claimed different portions of the land.
• Evidence submitted by the parties included:
• Constantino’s claim was primarily supported by his own testimony, corroborated by Sofronio Balubay, Proceso Andres, and Timoteo Miguel.
• Marcos Abig’s position was backed by his testimony, corroborated by Lino Pagulayan and Felix Baltazar.
• Honorata Cagumbay relied on her own testimonial evidence, further supported by Pagulayan’s testimony and a tax declaration (No. 26144) in the name of her father, Domingo Cagumbay, issued on February 27, 1941.
• Lino Pagulayan also testified, with Severo Balubay and Isabelo Camaya affirming his account.
• All claimants maintained that they had been in possession and had actively cultivated or cleared their respective claimed portions since 1921.

Judicial and Administrative Proceedings

• Constantino initiated legal actions to protect his claim:
• He filed an action for unlawful detainer against Marcos Abig in the Justice of the Peace Court of Solana, Cagayan.
• He filed an action to quiet title in the Court of First Instance against Lino Pagulayan, Honorata Cagumbay, and others.
• The Bureau of Lands, after investigating the adverse claims presented by both Constantino and the oppositors, found in favor of Constantino, overruling the claims of Abig, Cagumbay, and Pagulayan.
• The decision by the Bureau of Lands ordered that the disputing parties vacate the areas in contention within 60 days after notice of the decision.
• The Justice of the Peace Court rendered a favorable decision for Constantino, while the appeal in the ejectment case (Civil Case No. 108) was abandoned by Abig.
• The Department of Agriculture and Natural Resources later confirmed the decision of the Bureau of Lands on June 14, 1954, and denied the oppositors’ motion for reconsideration.
• Subsequently, on July 3, 1956, the oppositors (appellants) filed a petition for certiorari with the Court of First Instance of Cagayan challenging the decisions of the Director of Lands and the Secretary of Agriculture and Natural Resources on the grounds of grave abuse of discretion and lack of jurisdiction.

Contentions of the Appellants

• The appellants alleged that the decisions of the Director of Lands and the Secretary of Agriculture and Natural Resources were tainted by grave abuse of discretion.
• Specific allegations raised by the appellants included:
• The contention that Constantino’s homestead application should have been canceled for allegedly violating Section 90(e) of Act No. 141.
• An error in relying on the decision of the Justice of the Peace Court as support for the administrative findings.
• The failure to cancel Constantino’s application despite his not protesting the unlawful entry of the appellants into the land within six months, as required by Section 5 of Administrative Order No. 6.
• The mischaracterization of Marcos Abig as a mere tenant rather than someone with a bona fide adverse claim.
• The argument that the land applied for did not include the areas occupied by the appellants.

Findings and Judicial Outcome in the Lower Court

• The court reviewed the evidence and underscored that the decisions of the Director of Lands and the Secretary of Agriculture and Natural Resources were the product of a thorough investigation and were firmly based on factual findings.
• The lower court emphasized that any errors in estimating the effect of the evidence constituted errors in judgment rather than grave abuse of discretion.
• The court noted the principle that administrative decisions, once confirmed by the appropriate authorities, acquire a conclusive character and are not subject to review by certiorari.
• The petition for certiorari was dismissed with the costs being charged against the appellants.

Issue:

• Whether the petition for certiorari could validly annul the administrative decisions made by the Director of Lands and the Secretary of Agriculture and Natural Resources.
• Whether the decisions under review were rendered with grave abuse of discretion warranting judicial intervention.
• Whether the administrative findings concerning the homestead application, which were based on evidence presented and earlier judicial proceedings, should be considered conclusive and not subject to review by the courts.
• Whether the errors alleged by the appellants pertained merely to errors in judgment—specifically in the estimation of evidentiary value—and thus fell outside the scope of certiorari as an extraordinary remedy.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)