G.R. No. L-27811 - Lacson-Magallanes Co., Inc. vs. Pano

In 1932, Jose Magallanes was permittee and actual occupant of a 1,103-hectare pasture land in Tamlangon, Municipality of Bansalan, Province of Davao.
On January 9, 1953, Magallanes ceded his rights and interests in 392.7569 hectares of that land to Lacson-Magallanes Co., Inc.

On April 13, 1954, the ceded portion was released from the forest zone and officially declared agricultural land.
On January 26, 1955, Jose Pano and nineteen other claimants applied to purchase 90 hectares of the released area, alleging actual occupancy.
On March 29, 1955, the plaintiff corporation filed its own application to purchase the entire released area, prompting a protest by Pano et al.

July 31, 1956: The Director of Lands, after investigation, granted the plaintiff’s application and dismissed Pano’s claim; a motion for reconsideration was denied.
July 5, 1957: The Secretary of Agriculture and Natural Resources affirmed the Director’s decision on appeal by Pano and companions.
June 25, 1958: By authority of the President, Executive Secretary Juan Pajo modified the prior decisions—ordering allocation and subdivision of the northern portion of Block I (LC Map 1749, Project No. 27, Bansalan, Davao) to actual occupants, while preserving the corporation’s right to reimbursement for surveying costs.

The plaintiff filed a special civil action in the Court of First Instance praying that (a) the Secretary’s decision be declared binding and (b) the Executive Secretary’s order be declared void.
The Court of First Instance dismissed the complaint; the case was thereafter certified to the Supreme Court by the Court of Appeals under Sections 17 and 31 of the Judiciary Act of 1948, as amended.

Whether the Executive Secretary, acting by authority of the President, may reverse a factual decision of the Director of Lands that has been approved by the Secretary of Agriculture and Natural Resources, notwithstanding Section 4 of Commonwealth Act No. 141.
Whether delegation of the President’s power of control over executive departments to the Executive Secretary constitutes an undue delegation of constitutional authority.
Whether a department head equal in rank to other secretaries may intrude into the domain of another department’s decision-making when acting as the President’s alter ego.