Case Digest (G.R. No. L-23315)
Facts:
Desiderio S. Rallon v. Pacifico Ruiz, Jr., G.R. Nos. L-23315, L-23316, L-23317, L-23318, May 26, 1969, Supreme Court En Banc, Sanchez, J., writing for the Court. The consolidated dispute arose from four possessory actions filed in the Court of First Instance (CFI) of Bohol seeking recovery of possession over portions of Lot 46, Cadastral Case No. 15 (about 165 hectares) in San Antonio (now Sagbayan), Bohol. The CFI eventually dismissed the complaints on the ground that it had no jurisdiction because the Director of Lands had already taken administrative action concerning the same parcel.The factual background: a cadastral court in 1935 declared Lot 46 public forest. Prior to that, Jesus Vano had attempted registration (denied), and portions had been subject to a timber license and campsite permit issued to Josefa Rallon and Petrona Rallon. By a private document dated April 15, 1943, Josefa and Petrona purportedly transferred their possession rights to their nephews and niece—Desiderio S. Rallon, Vicente Rallon, Jr., Felicisima S. Rallon, and Cresencio S. Rallon (the plaintiffs). The Bureau of Forestry records did not show the plaintiffs as licensees or permittees; Josefa’s license had lapsed in 1941, and both aunts later died.
Various settlers (the defendants) occupied parts of Lot 46, were previously enjoined and punished for contempt after being ordered to restore possession to the Government following earlier litigation. Defendants filed applications for free patents (notarized in 1952, received by the District Land Office in 1953). Plaintiffs filed sales applications and protested defendants’ free patent applications on May 3, 1954. The Provincial Land Officer began factfinding in December 1954; hearings were continued and scheduled for 1955.
Before the Provincial Land Officer could complete the investigation, on August 26, 1955 the Rallons filed the present possessory suits in the CFI alleging illegal dispossession in March 1952 and asserting they derived possession from their aunts. The Director of Lands, made a defendant in each case, moved to dismiss for lack of jurisdiction; plaintiffs later moved to exclude the Director as a defendant and the CFI dismissed the cases as to the Director only (October 17, 1955), but otherwise proceeded.
The Bureau of Lands investigation resumed on the Director’s instruction in 1956; plaintiffs repeatedly failed to appear at critical hearings and the Provincial Land Officer found defendants to be actual occupants with improvements while plaintiffs had no occupation or improvements. On May 11, 1957 the Director of Lands dismissed plaintiffs’ protests and gave due course to defendants’ free patent applications; denial of reconsideration followed in September 1957. The Acting Secretary affirmed on January 13, 1958; plaintiffs’ belated motion for reconsideration was denied as untimely by Secretary Juan de G. Rodriguez on April 22, 1958 pursuant to Lands Administrative Order No. 6, Sec. 12. No appeal to the President was filed.
Plaintiffs sought certiorari in the CFI (June 10, 1958) to annul the administrative orders; on October 6, 1959 the CFI annulled the administrative decisions and ordered reinvestigation. Defendants obtained review in the Court of Appeals (CA-G.R. No. 26946-R) which on November 3, 1965 reversed the C...(Pro-only)
Issues:
- Do courts have jurisdiction to entertain possessory actions involving public land while administrative proceedings on disposition or patent applications are pending?
- Did the prior administrative decisions and the Court of Appeals' judgment render the plaintiffs' possessory actions moot or otherwise pr...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)