Case Digest (G.R. No. L-29421)
Facts:
In Rosito Bagunu v. Spouses Francisco Aggabao & Rosenda Acerit, G.R. No. 186487, decided on August 15, 2011, the petitioner Bagunu acquired by deed on November 24, 1987 a parcel of unregistered land in Caniogan, Sto. Tomas, Isabela, described as Lot 322, Pls-541-D, which substituted him as applicant on Atty. Samson Binag’s pending free patent application filed December 12, 1961 under Commonwealth Act No. 141 before the Bureau of Lands. The respondents, spouses Aggabao and Acerit, claimed prior title to the same tract by Deeds of Extrajudicial Settlement with Sale dated June 23, 1971 and April 15, 1979 from the heirs of Rafael Bautista, asserting Lot 322. On December 28, 1992 they protested Bagunu’s application before the Regional Office of the Department of Environment and Natural Resources (DENR), which, after ocular inspection, ruled on July 10, 1998 that Bagunu’s deed, though misidentified as Lot 322, actually covered Lot 258 and ordered Lot 322 excluded from his applicationCase Digest (G.R. No. L-29421)
Facts:
- Parties and Subject Land
- The Subject Land is an unregistered parcel in Caniogan, Sto. Tomas, Isabela, originally owned by Marcos Binag.
- Ownership chain:
- First sale: Marcos Binag → Felicisimo Bautista
- Second sale (1959): Bautista → Atty. Samson Binag, who applied for a free patent (Dec. 12, 1961) over “Lot 322.”
- Third sale (Nov. 24, 1987): Atty. Binag → Rosito Bagunu (petitioner), substituting as free patent applicant; deed described boundaries matching Lot 258 but misidentified as Lot 322.
- Administrative Protest and Proceedings
- Respondents Spouses Aggabao & Acerit filed protest (Dec. 28, 1992) to petitioner’s free patent, claiming Lot 322 by virtue of Extrajudicial Settlements with Sale (1971, 1979) from heirs of Rafael Bautista.
- DENR Regional Office investigation (ocular inspection) found petitioner occupying the disputed area. (July 10, 1998) Ordered:
- Respondents to file their own application for Lot 322.
- Petitioner’s application to exclude Lot 322.
- Relocation survey to delineate Lots 258 and 322.
- Motion for reconsideration denied; DENR Secretary (2004) affirmed that boundaries control over lot numbers, concluding petitioner acquired Lot 258, not Lot 322.
- Judicial Proceedings
- Court of Appeals (CA) affirmed DENR Secretary’s ruling, invoking doctrine of primary jurisdiction: DENR findings on land identity are entitled to great respect.
- Civil Case No. 751 before RTC (filed Nov. 22, 1994 by Atty. Binag for reformation of instruments):
- Claim that deeds misidentified Lot 258 as Lot 322; motion to dismiss held in abeyance.
- Respondents intervened with Quieting of Title/Reivindicacion/Damages, praying for adoption of DENR findings, reformation of deeds, exclusion of petitioner from Lot 322, and damages.
Issues:
- Jurisdiction and Competence
- Whether the DENR (through Bureau of Lands and Secretary) exceeded its jurisdiction by effectively reforming deeds and determining ownership over Lot 322, matters argued to fall exclusively within RTC jurisdiction.
- Whether the CA erred in applying the doctrine of primary jurisdiction, given that questions of contract interpretation and ownership are judicial in character and within RTC competence.
- Reviewability of Factual Findings
- Whether factual findings on identity of Lots 258 and 322 may be disturbed under Rule 45 of the Rules of Court.
- Whether petitioner sufficiently showed grave abuse of discretion or infirmity in DENR and CA factual conclusions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)