Facts:

This case, entitled "THE HON. ASST. EXECUTIVE SECRETARY FOR LEGAL AFFAIRS OF THE OFFICE OF THE PRESIDENT OF THE PHILIPPINES, THE BOARD OF LIQUIDATORS, AND THE DIRECTOR OF LANDS vs. THE HON. COURT OF APPEALS AND BASILIO MENDOZA," arose out of a protracted dispute concerning a parcel of land known as Lot No. 355, formerly Lot No. 336 in the Marbel Settlement, Cotabato. On April 15, 1948, Jesus M. Larrabaster applied to the National Land Settlement Administration (NLSA) for a home lot, which was approved on July 10, 1950. The lot, originally 1,500 square meters, was allocated to Larrabaster. Subsequently, he leased the lot to Basilio Mendoza while allowing Jorge Geller to squat on a part of it.

In 1952, the Land Settlement and Development Corporation (LASEDECO) took over the NLSA’s functions. Later on, Larrabaster assigned his rights to Jose B. Pena in 1956. Despite this transfer, Pena allowed Mendoza and Geller to remain on the property. On June 18, 1954, Republic Act N

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Facts:

Background and Initial Allocation

• In 1948, Jesus M. Larrabaster applied with the National Land Settlement Administration (NLSA) for a home lot in the Marbel Settlement District, Cotabato.
• His application was granted on 10 July 1950, and Home Lot No. 336 (later Lot No. 355) with an area of 1,500 square meters was allocated based on a report certifying that the lot was vacant and free from conflict.
• Larrabaster subsequently leased the property to Basilio Mendoza and allowed Jorge Geller to squat on a portion of the lot.

Transfer of Rights and Subsequent Developments

• On 25 November 1952, Land Settlement and Development Corporation (LASEDECO) succeeded the NLSA in overseeing land disposition.
• Larrabaster and his wife assigned their rights over the disputed property to Jose B. Pena on 29 June 1956, with Pena allowing Mendoza and Geller to remain on the property.
• A Supplementary Deed of Sale executed on 8 September 1956 defined the boundaries of the lot, describing its north, south, east, and west limits.

Administrative Changes and Requests for Adjustments

• Republic Act No. 1160 in June 1954 transferred custody of the Marbel Townsite to the National Resettlement and Rehabilitation Administration (NARRA).
• On 20 August 1956, Pena requested NARRA to approve the rights transfer; however, action was deferred in light of Proclamation No. 336, series of 1956, which returned disposition authority over unallocated lots to the Bureau of Lands.
• The Bureau of Lands’ inaction led Pena to approach the Board of Liquidators (BOL), which eventually confirmed his sale via Resolution No. 139, series of 1964.
• Recognizing that the actual area of the property had increased by accretion to 3,616.93 square meters, Pena sought an adjustment from the original 1,500 sq. meters but was denied by BOL’s Resolution No. 439, series of 1967.

The Role of the Office of the President and Subsequent Protests

• Feeling aggrieved, Pena appealed to the Office of the President.
• Following a review and a recommendation by the BOL that the subdivision of Lot No. 355 was appropriate, the Office of the President issued a Decision on 10 February 1969 that maintained a 1,500 sq. meter area, initially allocating the accretion to the Government.
• After Pena’s motion for reconsideration, the Office modified its decision on 13 May 1969, holding that the accretion benefits, pursuant to Article 457 of the Civil Code, should accrue to the owner and not to the Government.
• The BOL approved Resolution No. 236, series of 1969, and later recommended the issuance of a patent in Pena’s favor in September 1969.

Petitioner's Civil Actions and Further Judicial Proceedings

• Private respondent Mendoza, who had protested the subdivision and administrative decisions, filed a letter-protest on 1 August 1969 and sought redress through the administrative process, including a petition for reconsideration rendered negative on 28 September 1971.
• Concurrently, Mendoza resorted to judicial remedy by filing Civil Case No. 98 for Certiorari in January 1970 and later a Supplemental Petition.
• The Trial Court dismissed Mendoza’s petition on 10 May 1985, but the Court of Appeals reversed this decision on 28 November 1986, setting aside prior administrative decisions and ordering a reopening of the administrative case.

Submissions on Appeal

• Petitioners-public officials raised several submissions:
• Allegation of denial of due process to Mendoza in the administrative proceedings.
• Questioning whether the administrative decisions were supported by substantial evidence.
• Contention that the appellate setting aside of the decisions improperly ordered a reopening of administrative proceedings.
• The appellate court’s findings and subsequent order led to significant controversy regarding the due process and evidentiary bases of the administrative decisions.

Issue:

Due Process in Administrative Proceedings

• Whether the administrative decisions rendered by the Office of the President, particularly those of 10 February 1969, 13 May 1969, and 28 September 1971, violated Mendoza’s right to due process by not affording him proper notice or opportunity to be heard.
• Whether Mendoza’s filing of a letter-protest and subsequent motion for reconsideration fulfillment of procedural requirements was sufficient to cure any alleged defects in notice.

Substantial Evidence Supporting Administrative Rulings

• Whether the administrative decisions taken by the Office of the President were based on substantial and credible evidence, particularly the findings of the Board of Liquidators regarding the accretion of the property.
• The legitimacy of relying on the BOL’s report and the technical determination of the lot’s boundary and area in resolving the dispute over accretion.

Authority to Disposition and Effects of Accretion

• Whether, under Article 457 of the Civil Code, the benefits of accretion should accrue to the owner (Pena) when the property had already been transferred and whether the Government’s claim to the accreted area is tenable.
• Whether the subdivision of the disputed property by the Bureau of Lands, which resulted in the allocation of three lots, was within the scope of the Bureau’s authority under Proclamation No. 336, series of 1956.

Reopening of Administrative Case

• Whether the Court of Appeals erred in ordering a reopening of the administrative case by setting aside the previous administrative and trial court decisions, thereby affecting the finality of administrative judgments.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)