Facts:

This case involves Santiago Balmonte as the plaintiff-appellee against defendants-appellants Julian Marcelo and Alejandro Marcelo. The events leading to this appeal began in 1937 when Balmonte applied for a homestead patent for Lot 2808 in the Santiago (Isabela) B.L. Cadastre-211. In 1947, Alejandro Marcelo submitted a homestead application for the same lot, causing a conflict that prompted the District Land Officer of Isabela to initiate an investigation. Marcelo failed to appear despite receiving notifications, leading to the dismissal of his claims in 1948. As a result, Balmonte was granted a homestead patent on May 28, 1949, followed by Original Certificate of Title No. P-692 on June 10, 1949. Marcelo later protested the issuance of Balmonte's patent. The Director of Lands ordered another investigation on August 27, 1949, but before it could conclude, Balmonte filed a case in the Court of First Instance of Isabela on November 7, 1953, seeking recovery of possession and d

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Facts:

Background and Applications

• In 1937, appellant Balmonte applied for a homestead patent covering Lot 2808 of the Santiago (Isabela) B.L. Cadastre-211.
• In 1947, defendant-appellant Alejandro Marcelo filed a separate homestead application for the very same lot, leading to an inevitable conflict between the two claims.

Administrative Investigation and Issuance of Title

• In view of the conflict, the District Land Officer of Isabela conducted an investigation in 1948.
• Marcelo failed to appear despite being served notices, leading to a dismissal of his claims and application.
• As a result, Balmonte was issued a patent on May 28, 1949, followed by the issuance of Original Certificate of Title No. P-692 on June 10, 1949.
• Marcelo protested the issuance of Balmonte’s patent, prompting further administrative action.
• On August 27, 1949, the Director of Lands ordered another investigation into Marcelo’s protest.

Filing of the Civil Case by Balmonte

• On November 7, 1953, while the investigation by the District Land Officer was still underway, Balmonte filed the case in the Court of First Instance of Isabela.
• The suit was for reivindicacion, seeking recovery of possession of the land and damages.
• The complaint alleged that in 1950, during Balmonte’s temporary absence, defendant Marcelo—and by extension his father, Juan Marcelo—illegally entered the property and refused to surrender it.

Proceedings in the Court of First Instance

• The defendants (the Marcelos) raised several defenses in their answer, including:
• Contesting the jurisdiction of the court due to the pending administrative investigation.
• Denying Balmonte’s prior possession and cultivation of the land.
• Questioning the validity of Balmonte’s patent and certificate of title.
• Counterclaiming for damages.
• On September 15, 1955, the Director of Lands decided the administrative dispute.
• The decision found that the Marcelos' occupation was in bad faith.
• The Marcelos were held to be in estoppel for their failure to appeal the outcome of the 1948 investigation.
• Believing the Director’s decision was final, the Court of First Instance granted summary judgment in favor of Balmonte.
• On July 17, 1956, the court rendered a decision:
• Declaring Balmonte the absolute owner of the land.
• Ordering the Marcelos to surrender possession and vacate the premises.
• In a supplemental decision in 1957, the Marcelos were further ordered to pay:
• P4,200.00 in damages, plus
• P700.00 per agricultural year from 1957 until the actual surrender of the property.

Subsequent Appeals and Administrative Developments

• The Marcelos appealed the Court of First Instance decision to the Supreme Court.
• On April 25, 1961, the Supreme Court set aside the 1956 decision on the ground that the decision of the Director of Lands was not final—since it was seasonably appealed to the Secretary of Agriculture and Natural Resources—and remanded the case back for further proceedings.
• Further Administrative Actions:
• On May 18, 1961, the Secretary of Agriculture dismissed the Marcelos’ appeal against the Director’s decision.
• Unhappy with this result, Alejandro Marcelo further appealed, and on June 4, 1962, through the Assistant Executive Secretary, the President affirmed the decision of the Secretary of Agriculture.
• Rehearing and Subsequent Motions:
• The case was set for rehearing in the lower court.
• At the fixed date, counsel for the defendants moved, orally, for a continuance to file an amended answer to plead lack of notice and alleged fraud.
• They argued that the Marcelos were not really notified of the 1948 investigation.
• The motion for continuance was denied, and the hearing proceeded.
• Post-hearing Developments in Rehearing:
• The lower court rendered a decision on July 30, 1962, reaffirming and reinstating the original 1956 judgment in favor of Balmonte.
• Defendants subsequently filed a motion for reconsideration which was received one day after the decision, followed by a supplemental motion for reconsideration on August 6, 1962, attaching a purported amended answer alleging:
• A lack of actual notice to Alejandro Marcelo regarding the 1948 investigation and dismissal order.

ii. Fraud in making Marcelo admit receipt of the order. iii. That no reinvestigation was made in 1949 as directed, and that the Lands investigator’s reports were fabricated or falsified. iv. An allegation of grave abuse of discretion by the Director of Lands in dismissing Marcelo’s claims.

Issue:

• Whether the Court of First Instance committed reversible error in refusing to allow the defendants-appellants to amend their answer to plead a lack of notice regarding the 1948 investigation, as well as allegations of fraud and irregularities in the administrative process.

• Whether the defendants' failure to timely plead these issues—and the subsequent reliance instead on their appeal to the Secretary of Agriculture and the President—justifies the rejection of the amended answer on procedural and substantive grounds.

• Whether the decisions rendered by the executive agencies (specifically the Director of Lands, the Secretary of Agriculture, and the affirmation by the President) are beyond judicial review, given that they pertain to factual determinations made within the administrative investigation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)