Case Digest (G.R. No. L-12460)
Facts:
- Eusebio Constantino filed a homestead application for a parcel of land in Solana, Cagayan in 1946.
- Marcos Abig, Honorata Cagumbay, and Lino Pagulayan claimed different portions of the land.
- The Bureau of Lands conducted an investigation and found that Constantino's application should be given due course.
- Abig, Cagumbay, and Pagulayan appealed to the Department of Agriculture and Natural Resources, but their appeal was denied.
- They filed a petition for certiorari with the Court of First Instance of Cagayan, alleging that the decisions of the Bureau of Lands and the Department of Agriculture and Natural Resources were rendered with grave abuse of discretion.
- The court dismissed their petition, stating that the decisions of the public officials were conclusive and not subject to judicial review.
- The court also noted that the appellants were in estoppel to attack the decisions, as they had previously agreed to respect and submit to the decisions of the Bureau of Lands and the Department of Agriculture and Natural Resources.
- The appellants appealed the decision to the Supreme Court.
Issue:
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Ruling:
- The decisions of the public officials are conclusive and not subject to judicial review.
- A petition for certiorari can only succeed if it is based on jurisdictional grounds, and any error committed by the respondent in the exercise of their jurisdiction can only be reviewed or corrected by appeal.
- Abuse of discretion is a ground for certiorari, but not every error in the proceeding or every erroneous conclusion of law or fact constitutes abuse of discretion.
- Errors in the appreciation of evidence cannot be reviewed by certiorari.
- The decisions of the public officials were based on their discretion and judgm...(Unlock)
Ratio:
- De...continue reading
Case Digest (G.R. No. L-12460)
Facts:
On February 11, 1946, Eusebio Constantino filed a homestead application (No. D-366; E-D-385) for a parcel of land approximately 24 hectares in size, located in Barrio Nangalisan, Solana, Cagayan. This application was a reconstitution of a previous one submitted in 1924, which had been lost during World War II along with other records. The original application was processed as H. A. No. 401426, and the land was surveyed in 1930. However, due to uncertainties regarding the land's area at the time of the 1946 application, a relocation survey was conducted. During this survey, Marcos Abig, Honorata Cagumbay, and Lino Pagulayan claimed various portions of the land. The Bureau of Lands investigated these claims, where Constantino presented evidence including his testimony and that of several witnesses, while Abig, Cagumbay, and Pagulayan also provided their testimonies and supporting documents, including tax declarations.
In 1946, Constantino initiated an unlawful detainer action against Abig in the Justice of the Peace Court, and a separate action to quiet title against Pagulayan, Cagumbay, and others in the Court of First Instance. The unlawful detainer case was decided in Constantino's favor, but Abig's appeal was later abandoned. The second case was dismissed after the parties agreed to submit to the Bureau of Lands' decision regarding Constantino's homestead application. The Bureau of Lands ultimately ruled in favor of Constantino, ordering the oppositors to vacate the disputed areas. This decision was affirmed by the Department of Agriculture and Natural Resources on June 14, 1954. The appellants' motion for reconsideration was denied, leading them to file a petiti...