Title
Agura vs. Serfino Sr.
Case
G.R. No. 50685
Decision Date
Dec 4, 1991
The court upheld the validity of the sale of public foreshore lands for residential use, dismissing claims of illegality based on land classification and area limitations.
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Case Digest (G.R. No. 50685)

Facts:

  • Petitioners: Roberto Agura, Cesar Alib, Tomas Sta. Rita, Alfredo Cordova, Victor de los Reyes, and Marina Serfino.
  • Respondents: Federico Serfino, Sr., Federico Serfino, Jr., Honorable Ronaldo B. Zamora, Honorable Jose J. Leido, Jr., and the Court of First Instance of Manila, Branch XXI.
  • On December 10, 1965, Federico Serfino, Sr. filed Miscellaneous Sales Application (MSA) No. (V-3)2 for a 4,172 square meter parcel of land in San Patricio, Bacolod City.
  • Federico Serfino, Jr. filed MSA No. (V-3)1 for an adjoining lot of 1,358 square meters on February 18, 1966.
  • The Director of Lands approved the survey plans, noting significant improvements made by the Serfinos since 1947.
  • A public auction on December 27, 1967, saw the Serfinos as the only qualified bidders, successfully bidding P20,860.00 and P6,790.00.
  • Despite full payment, the Bureau of Lands did not issue an award for the lots.
  • Petitioners claimed occupation of portions of the land for over thirty years and petitioned the President for the land.
  • Investigations revealed the land formed from accretions and was now dry land.
  • The Director of Lands initially favored the petitioners but was overruled by the Secretary of Natural Resources, who upheld the validity of the auction.
  • The trial court affirmed this decision on April 30, 1979, prompting the petitioners to seek a Supreme Court review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed the petition and affirmed the trial court's decision dated April 30, 1979.
  • The Court ruled that the findings of the public officials were not arbitrary and did not constitute grave abuse of discretion.
  • It held that Republic Act No. 730 did not r...(Unlock)

Ratio:

  • The Supreme Court noted that the powers of the Secretary of Natural Resources regarding public land disposition are administrative and discretionary.
  • Courts typically do not interfere unless there is clear evidence of arbitrar...continue reading

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