Title
Aggabao vs. Gamboa
Case
G.R. No. L-54760
Decision Date
Aug 30, 1982
Dispute over 32-hectare lots in Escalante, Negros Occidental; Gamboas' homestead claims upheld over Aggabao's prewar sales claims; administrative decisions deemed conclusive, res judicata applied.
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Case Summary (G.R. No. L-54760)

Background of the Case

  • The case involves a dispute over Lots Nos. 2687 and 268B in Escalante, Negros Occidental, claimed by Leticia U. Gamboa and Pedro U. Gamboa under their homestead applications, while Micaela Aggabao asserts that the lots were covered by her parents' pre-war sales applications.
  • The Director of Lands issued a decision on November 8, 1956, affirming that the lots were adjudicated to the Gamboas in two pre-war decisions dated February 13, 1938, and dismissed the claims of Aggabao and the heirs of Bartolome Celestial.
  • Aggabao's appeal was subsequently affirmed by the Secretary of Agriculture, the Acting Executive Secretary, the Court of First Instance, and the Court of Appeals.

Legal Arguments Presented

  • Aggabao contended that the Appellate Court erred in accepting the secondary evidence presented by the Gamboas regarding the Director's 1938 decisions and ignored the 1953 finding by the district land officer that she had a preferential right to purchase the lots.
  • She also alleged that the Gamboas fraudulently acquired possession of the lots.

Supreme Court's Ruling on Appeal

  • The Supreme Court ruled that Aggabao's appeal could not be sustained due to the conclusive nature of the factual findings made by the Director of Lands, which were affirmed by the Secretary of Agriculture and other administrative bodies.
  • The Court emphasized that the factual conclusions of administrative agencies are binding and cannot be re-evaluated by the courts unless there is a clear showing of excess of jurisdiction.

Conclusiveness of Administrative Findings

  • The Court reiterated that the findings of the Director of Lands regarding the Gamboas' priority as homesteaders are conclusive under Section 4 of the Public Land Law (Commonwealth Act No. 141).
  • The affirmation of these findings by the Acting Executive Secretary further precludes the reviewing court from weighing conflicting evidence or substituting its judgment for that of the administrative agency.

Court of Appeals' Role

  • The Court of Appeals confirmed the findings of the administrative officials and the trial court, establishing that its judgment is generally conclusive as to the facts and not subject to review by the Supreme Court.
  • Aggabao failed to raise substantial legal issues that would warrant a review under Section 4 of Rule 45 of the Rules of Court.

Res Judi...continue reading


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