Title
Aggabao vs. Gamboa
Case
G.R. No. L-54760
Decision Date
Aug 30, 1982
Dispute over 32-hectare lots in Escalante, Negros Occidental; Gamboas' homestead claims upheld over Aggabao's prewar sales claims; administrative decisions deemed conclusive, res judicata applied.
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Case Digest (G.R. No. L-54760)

Facts:

1. Subject of the Controversy:
The dispute involves Lots Nos. 2687 and 2688 of the Escalante, Negros Occidental cadastre, with a combined area of thirty-two hectares.

2. Claims of the Parties:

  • Leticia U. Gamboa and Pedro U. Gamboa (Respondents):
    They claim that the lots are covered by their respective homestead applications (Nos. 199050 and 199051).
  • Micaela C. Aggabao (Petitioner):
    She asserts that the lots were covered by her parents' prewar sales applications.

3. Administrative Proceedings:

  • The Director of Lands, in a decision dated November 8, 1956, found that the lots were adjudicated to the Gamboas in two prewar decisions dated February 13, 1938.
  • The 1956 decision dismissed the claims of Micaela Aggabao and the heirs of Bartolome Celestial.

4. Judicial Proceedings:

  • Aggabao appealed the 1956 decision, but it was affirmed by the Secretary of Agriculture and Natural Resources, the Acting Executive Secretary, the Court of First Instance of Manila, and the Court of Appeals.
  • Aggabao further appealed to the Supreme Court, arguing that the Court of Appeals erred in giving probative value to the Gamboas' secondary evidence and disregarding the 1953 decision of the district land officer in Bacolod City, which favored her.

Issue:

  • (Unlock)

Ruling:

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Ratio:

  1. Administrative Decisions are Conclusive:
    Under Section 4 of the Public Land Law (Commonwealth Act No. 141), the Director of Lands has the exclusive authority to adjudicate rights over public lands. The courts cannot review such administrative decisions unless there is a clear showing of excess of jurisdiction.

  2. Res Judicata Applies:
    The prewar decisions of the Director of Lands in favor of the Gamboas, which were not appealed and were found to be authentic, have the force of res judicata. This principle bars the re-litigation of issues that have already been conclusively decided.

  3. No Substantial Legal Issues Raised:
    Aggabao failed to raise substantial legal issues in her appeal. Her petition did not meet the requirements under Section 4 of Rule 45 of the Rules of Court.


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