Title
Besaga vs. Acosta
Case
G.R. No. 194061
Decision Date
Apr 20, 2015
Dispute over SLUP for timberland lots in Palawan; procedural lapses in appeal deemed non-prejudicial, upholding liberal construction of administrative rules for substantial justice.
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Case Digest (G.R. No. 194061)

Facts:

Background of the Case: The dispute involves Lot Nos. 4512 and 4514 located in Barangay Port Barton, San Vicente, Palawan, which are part of a six-hectare timberland. Both Emelie L. Besaga (petitioner) and spouses Felipe and Luzviminda Acosta (respondents) applied for a Special Land Use Permit (SLUP) for these lots. The petitioner claimed that the lots were covered by Tax Declaration No. 048 in the name of her late father, Arturo Besaga, Sr., who allegedly occupied the land during his lifetime. The respondents, on the other hand, claimed they acquired the lots through a waiver of rights from registered survey claimants.

Administrative Proceedings:

  • On February 11, 2003, the petitioner applied for an SLUP for Lot Nos. 4512, 4513, and 4514.
  • On February 13, 2003, the respondents also applied for an SLUP for Lot Nos. 4512 and 4514.
  • On December 1, 2003, the DENR Regional Executive Director (RED) granted the petitioner's SLUP application and rejected the respondents' application.
  • The respondents appealed to the DENR Secretary, who initially ruled in their favor but later reversed his decision, stating that the respondents failed to perfect their appeal by filing a Memorandum of Appeal instead of a Notice of Appeal.
  • The Office of the President reversed the DENR Secretary's decision, and the Court of Appeals (CA) affirmed the Office of the President's ruling.

Key Documents:

  • Tax Declaration No. 048 (petitioner's claim).
  • Affidavit of Waiver of Rights executed by Rogelio Maranon (respondents' claim).
  • Joint Affidavit of Waiver of Rights executed by Arturo Besaga, Jr. and Digna Matalang Coching (respondents' claim).

Issue:

The petitioner raised the following issues:

  1. Whether the respondents' appeal to the DENR Secretary was correctly filed instead of to the Regional Office as required by Section 1(a) of DENR Department Administrative Order (DAO) No. 87, series of 1990.
  2. Whether the respondents' appeal was perfected despite their failure to comply with Section 1(a) of DAO No. 87.
  3. Whether the liberal interpretation of the rules on appeal in administrative proceedings was correctly applied by the CA.
  4. Whether the orders of the RED dated December 1, 2003, and July 26, 2004, were already final and executory.
  5. Whether the perfection of appeal under Section 1(a) of DAO No. 87 is mandatory and jurisdictional.
  6. Whether the orders of the RED can still be modified or set aside by the CA.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court upheld the CA's decision, ruling that the respondents' procedural errors did not warrant the dismissal of their appeal. The Court emphasized the importance of liberal construction of administrative rules to ensure fairness and justice, especially when no due process violations are present.


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