G.R. No. L-36847 - Yngson vs. Secretary of Agriculture and Natural Resources

The disputed subject matter involves approximately 66 hectares of mangrove swamps located in sitio Urbaso, barrio Mabini, municipality of Escalante, Negros Occidental, intended for conversion into fishponds.
Originally, several applicants sought the opportunity to develop the area as fishponds. Early applications by Teofila L. de Ligasan (January 14, 1946) and Custodio Doromal (October 28, 1947) were rejected because the area was then classified as a communal forest and not yet available for fishpond purposes.

Petitioner-appellant Serafin B. Yngson filed his application on March 19, 1952.
Respondents-appellees Anita V. Gonzales and Jose M. Lopez filed their respective applications on March 19, 1953, and April 24, 1953, respectively.

The swampland was formally released for fishpond development on January 14, 1954, revealing that all five applications had been submitted prematurely when the land was still forest land.
Responding to the conflicting claims, the Director of the Bureau of Fisheries issued an order on April 10, 1954, awarding the entire area to Yngson based on his asserted priority rights.
Subsequent administrative appeals by Gonzales and Lopez led to the Department of Agriculture and Natural Resources, through an order dated April 5, 1955, setting aside the Director’s initial award and dividing the area equally into three portions, awarding one-third share to each applicant.
Petitioner Yngson subsequently filed a petition for review seeking the annulment of the division order and the reinstatement of the Director’s award in his favor.
The Court of First Instance of Negros Occidental dismissed Yngson’s petition on the ground that he failed to establish a “capricious and whimsical exercise of judgment” warranting judicial intervention in what was deemed a special civil action review.
Yngson raised the following assignments of error:

That the lower court erred in finding no grave abuse of discretion by the administrative agencies.
That the lower court improperly sustained the administrative order which treated all applications as equal despite the “priority rule” under Fisheries Administrative Order No. 14.
That the lower court erred in dismissing his complaint.

During the pendency of the petition, Yngson also filed a motion for contempt alleging unauthorized entry and construction by other respondents on portions of the disputed area; this motion was ultimately denied as it raised issues and factual disputes more appropriate for trial proceedings.

Was there a grave abuse of discretion on the part of the administrative agencies in interpreting and applying the provisions of Fisheries Administrative Order No. 14, specifically regarding the “priority rule”?

Did the agencies err in awarding Yngson the entire area initially based on a perceived priority despite all applications being premature?
Was the subsequent decision to equally divide the area among the petitioners (Yngson, Gonzales, and Lopez) a sound exercise of administrative discretion given that the applications were filed before the area was available for fishpond purposes?