Title
Bagunu vs. Spouses Aggabao
Case
G.R. No. 186487
Decision Date
Aug 15, 2011
Land dispute over Lot 322: DENR ruled petitioner wrongfully included it in free patent application; SC upheld DENR's jurisdiction, deferring to its technical expertise.
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Case Digest (G.R. No. 186487)

Facts:

Background of the Land Dispute

The dispute arose from a protest filed by spouses Francisco Aggabao and Rosenda Acerit (respondents) against Rosito Bagunu’s (petitioner) free patent application over an unregistered parcel of land in Caniogan, Sto. Tomas, Isabela. The land was previously owned by Marcos Binag, sold to Felicisimo Bautista, then to Atty. Samson Binag, who applied for a free patent in 1961. In 1987, Atty. Binag sold the land to the petitioner, who continued the free patent application.

Identification of the Land

The deeds of sale and surveys identified the land as Lot 322. However, in 1992, the respondents protested, claiming ownership of Lot 322 based on deeds executed by the heirs of Rafael Bautista.

DENR Investigation and Findings

The DENR Regional Office found that the petitioner occupied and cultivated the disputed land, including the area claimed by the respondents. However, it ruled that the petitioner wrongfully included Lot 322 in his application, as it belonged to the respondents. The DENR ordered:

  1. The respondents to file a public land application for Lot 322.
  2. The petitioner’s application to exclude Lot 322.
  3. A relocation survey to determine the exact boundaries of Lots 258 and 322.

Court Proceedings

The petitioner appealed to the DENR Secretary, who affirmed the ruling, concluding that the petitioner actually acquired Lot 258, not Lot 322. The Court of Appeals (CA) also affirmed, citing the DENR’s primary jurisdiction over public lands.

Civil Case for Reformation of Instruments

Atty. Binag filed a civil case for reformation of the deeds of sale, claiming they erroneously identified the land as Lot 322 instead of Lot 258. The respondents intervened, seeking quieting of title and damages.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction of the DENR: The DENR has exclusive authority over public lands, including determining the identity of disputed lots. The petitioner’s acknowledgment of the land as public by filing a free patent application confirms this.
  2. Doctrine of Primary Jurisdiction: Courts must defer to administrative agencies in matters requiring specialized knowledge, such as land disputes. The DENR’s findings on the identity of Lots 258 and 322 are conclusive.
  3. Reformation of Contracts: While reformation of contracts falls under court jurisdiction, the RTC must suspend proceedings pending the DENR’s final determination of the land dispute.


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