G.R. No. 142612 - Angeles vs. Secretary of Justice

Petitioner Ambrosio Salud alleged that he was the successor in interest of the original applicant who paid the first installment of the purchase price for a parcel of land.
The disputed parcel of land is part of the Sta. Cruz de Malabon Friar Land Estate and is located in Quintana, Tanza, Cavite.

Salud sought recognition of his right over the land from the Director of Lands.
His claim was initially successful, with the decision being confirmed by the then Secretary of Agriculture and Natural Resources.
On appeal, the Executive Secretary reversed that decision by holding that the land was open for public sale to the highest bidder.

Not satisfied with the Executive Secretary's decision, the petitioner instituted a special civil action for certiorari and mandamus.
The petition aimed to set aside and annul the executive decision affecting his interest in the land.

The Court of First Instance of Manila, under Judge Agustin P. Montesa, dismissed the suit on the ground that the land being located in Tanza, Cavite rendered the Manila court without jurisdiction.
The judge’s reasoning was based on the traditional view that a suit “affecting title to, or for recovery of possession of real property” should be filed where the property is situated.

The crucial issue on appeal was whether a petition for review of an administrative decision should be filed in the court of the officer’s office (in this case, Manila) or where the property is located.
The appellate court noted that the lower court’s dismissal conflicted with settled jurisprudence concerning the jurisdiction of the Court of First Instance in such matters.

Dizon v. Bayona – involving a fishpond permit dispute in Batangas.
Sarabia v. The Secretary of Agriculture and Natural Resources – concerning a fishpond permit issued for land in Oriental Mindoro.
Suarez v. Reyes – dealing with a timber concession in Zamboanga del Norte.
Uichanco v. Secretary of Agriculture and Natural Resources – involving a sales application for public land in Oriental Mindoro.
Extensive Enterprises Corp. v. Sarbro & Co., Inc. – addressing a dispute over a public forest area in Davao.

These cases consistently reaffirmed the jurisdiction of the Manila court to decide issues arising from executive decisions, irrespective of the location of the land.

Whether a petition for review (certiorari and mandamus) of an administrative decision should be filed in the court where the officer who rendered the decision has his office (the Court of First Instance of Manila) despite the property’s location in another province.
Whether the dismissal of the suit in the Court of First Instance of Manila on the basis of territorial limitation constitutes a proper exercise of judicial discretion given the established jurisprudence.

Whether prior decisions (e.g., Dizon, Sarabia, Suarez, Uichanco, and Extensive Enterprises) that affirm the jurisdiction of Manila courts in similar disputes should control the present case.
Whether the doctrine that supports the filing of such petitions in the Manila court is binding in this case.