Case Summary (G.R. No. L-14834)

Jurisdiction of the Board of Liquidators

• The Board of Liquidators holds exclusive authority to manage and dispose of lands under its administration.
• Courts lack the power to review the Board's decisions unless through special civil actions such as certiorari or prohibition.
• Direct actions for annulment of the Board's decisions are not permissible unless there is a claim of abuse of discretion or lack of jurisdiction.

Authority to Cancel Sales Contracts

• Under Republic Act No. 477, the Board of Liquidators is empowered to either cancel or approve sales contracts concerning lands it administers.
• The case revolves around the Board's authority to cancel a sale executed by the National Abaca and Other Fibers Corporation (NAFCO) in favor of Tomas Alvarez.

Background of the Case

• The Court of First Instance of Davao ruled that the Board of Liquidators lacked jurisdiction to cancel the sale to Tomas Alvarez, declaring the Board's resolution null and void.
• The case involved a sale of Lot No. 52 of the Daliaon Plantation, which the Board canceled, claiming that Alvarez had defaulted on payments and was not in possession of the land.

Procedural History and Defenses

• The defendants moved to dismiss the case, arguing that the court lacked jurisdiction and that the plaintiffs had not exhausted administrative remedies.
• The Board's resolution to cancel the sale was based on an investigation that the plaintiffs contested, claiming it was biased and lacked due process.

Stipulation of Facts

• The parties submitted a stipulation of facts detailing the timeline of events, including notices sent to the plaintiffs and their responses.
• The stipulation included evidence of the Board's investigation and the plaintiffs' refusal to participate, which the Board interpreted as a lack of compliance.

Court's Findings on Due Process

• The trial court found that the Board's actions violated due process by conducting an ex-parte investigation without allowing Alvarez to present his case.
• The court emphasized the importance of giving the plaintiff an opportunity to be heard before canceling the sale.

Appellate Review of Errors

• The defendants appealed, asserting that the trial court erred in its jurisdiction, in failing to require exhaustion of administrative remedies, and in its interpretation of the Board's powers.
• The appellate court noted that the trial court's jurisdiction was indeed limited regarding the Board's administrative decisions.

Conclusion on Board's Authority

• The appella...continue reading

Case Syllabus (G.R. No. L-14834)

Case Background

• This case involves an appeal from the Court of First Instance of Davao, presided over by Hon. Wenceslao L. Fernan.
• The plaintiffs, Tomas Alvarez and Francisco Basilio, filed a civil action against the Board of Liquidators regarding a contract of sale for Lot No. 52 of the Daliaon Plantation, originally executed by the National Abaca and Other Fibers Corporation (NAFCO).
• The Board of Liquidators had previously cancelled the sale and ordered the forfeiture of payments made by Alvarez, declaring a portion of the lot vacant and disposable by lottery.

Procedural History

• The complaint challenged the authority of the Board of Liquidators to cancel the sale and alleged that the Board's resolution was null and void.
• The Board of Liquidators moved to dismiss the action, claiming lack of jurisdiction and that the plaintiffs had not exhausted administrative remedies. This motion was denied.
• The Board then answered the complaint, denying the allegations and asserting special defenses related to the legality of the sale and administrative procedures followed.

Key Facts

• The administrative investigation was conducted with the plaintiffs absent, which they protested, claiming partiality from the investigator.
• The investigation concluded that Alvarez was never in possession of the land and was merely a “dummy” for Basilio, ...continue reading