Title
Gayacao vs. Executive Secretary of the President of the Philippines
Case
G.R. No. L-21066
Decision Date
Apr 30, 1965
The Supreme Court reinstates Maria A. Gayacao's complaint, affirming judicial review and the requirement for access to justice against government officials' non-compliance with the law.
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Case Digest (G.R. No. L-21066)

Facts:

  • Maria A. Gayacao is the petitioner and appellant against several respondents, including the Hon. Executive Secretary of the President of the Philippines, the Hon. Secretary of Agriculture and Natural Resources, the Director of Lands, and Felixberto Alcarmen.
  • On January 2, 1962, Gayacao filed a complaint in the Court of First Instance of Basilan City (Special Civil Case No. 322).
  • She claimed the right to purchase residential Lots No. 55 and 56 in Isabela, Basilan City, through Miscellaneous Sales Application No. 8558, which was received by the Bureau of Lands.
  • Gayacao asserted she paid necessary installments, and her application was recommended for approval on October 24, 1939.
  • She improved the lots, paid taxes, and maintained possession.
  • After World War II, Felixberto Alcarmen, a war refugee, was allowed to temporarily occupy part of the lots.
  • Alcarmen later filed his own Miscellaneous Sales Application No. V-8113 for Lot 55.
  • In 1949, the Director of Lands approved Alcarmen's application without considering Gayacao's prior rights, which she argued violated her rights and Section 81 of Commonwealth Act 141.
  • Gayacao sought remedies including annulment of the Director of Lands' decision, approval of her original application, and eviction of Alcarmen.
  • The respondents filed a motion to dismiss, claiming the Court of First Instance lacked jurisdiction over the case.
  • The court granted the motion and dismissed Gayacao's petition on December 3, 1962, leading her to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Maria A. Gayacao, reversing the lower court's order of dismissal.
  • The Court held that the dismissal was a reversible error and that the Court of First...(Unlock)

Ratio:

  • The Supreme Court reasoned that Gayacao's complaint challenged the legality of the administrative decisions made by the Director of Lands and affirmed by the other respondents.
  • The Court emphasized the principle of judicial review, allowing courts to assess the constitutionality of legislative and administrative actions....continue reading

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