G.R. No. 194061 - Besaga vs. Acosta

The dispute involves Lot Nos. 4512 and 4514 in Barangay Port Barton, San Vicente, Palawan, part of a six-hectare timberland.
Emelie L. Besaga (petitioner) applied for a Special Land Use Permit (SLUP) for Lot Nos. 4512, 4513, and 4514 on February 11, 2003, claiming ownership through her late father’s Tax Declaration No. 048.
Respondent spouses Felipe and Luzviminda Acosta applied for an SLUP for Lot Nos. 4512 and 4514 on February 13, 2003, asserting their rights through waivers executed by previous claimants.
The DENR Regional Executive Director (RED) initially favored the petitioner, issuing orders on December 1, 2003, and July 26, 2004, rejecting the respondents' application.

The respondents filed an appeal to the DENR Secretary after the RED's orders, but the RED later issued a Certificate of Finality, declaring the orders final due to the respondents' failure to file a Notice of Appeal.
The DENR Secretary later vacated the RED's orders, favoring the respondents, but reversed this decision upon reconsideration, citing procedural errors in the appeal process.
The Office of the President ultimately reversed the DENR Secretary's reconsideration, affirming the respondents' rights based on the waivers and the merits of the case.

The RED's initial ruling favored the petitioner based on Tax Declaration No. 048 and testimonies from local officials.
The DENR Secretary later found that the petitioner could not claim preferential rights over Lot Nos. 4512 and 4514, questioning her claim of tacking possession from her father.
The DENR Secretary recognized the respondents' preferential rights based on valid waivers from previous claimants.

The Office of the President ruled that the respondents' appeal was valid despite procedural missteps, emphasizing that the appeal memorandum served as sufficient notice of intent to appeal.
It noted that the appeal fees were paid, and the procedural errors did not violate due process.
The Office of the President found that the Tax Declaration cited by the petitioner did not cover the disputed lots.

The Court of Appeals upheld the Office of the President's decision, emphasizing the liberal interpretation of procedural rules in administrative proceedings.
It ruled that the RED's orders had not attained finality and that the procedural lapses did not warrant dismissal of the appeal.

The petitioner contended that the respondents failed to perfect their appeal, arguing that strict compliance with procedural rules is mandatory and jurisdictional.
She asserted that the liberal interpretation of rules was inapplicable due to the respondents' failure to comply with the required procedures.

The respondents argued for the dismissal of the petition, asserting that the CA acted correctly in upholding the Office of the President's ruling.
They maintained that strict adherence to technicalities should not override the determination of substantive rights.

The petitioner raised several issues regarding the correctness of the appeal process, the perfection of the appeal, the application of liberal interpretation of rules, and the finality of the RED's orders.