Title
Galindez vs. Firmalan
Case
G.R. No. 187186
Decision Date
Jun 6, 2018
Salvacion Firmalan’s 1949 land application granted priority over Alicia Galindez’s 1964 claim, as possession alone under the Public Land Act does not confer ownership rights.

Case Summary (G.R. No. 187186)

Chronology of Applications and Initial Findings

Salvacion Firmalan filed her first application for the 150-m² parcel on May 16, 1949, docketed as Miscellaneous Sales Application (MSA) No. V-7861. Although the District Land Office recognized the lot's suitability for residential purposes and recommended approval, a reappraisal ordered in 1950 was never undertaken. Almost eighteen years later, on April 25, 1967, Firmalan filed a second application for the larger Lot No. 915, which encompassed her first application. The Acting District Land Officer again recommended approval.

Alicia Galindez protested this second application, asserting she and her family had been occupying a portion of the lot since November 1951, had built improvements thereon, and filed her own application (MSA No. (V-6) 44) on February 20, 1964. This conflict led to the suspension of action on Firmalan’s application pending investigation.

Investigation and Land Examiner Reports

A formal investigation by Land Inspector Mabini Fabreo initially reported occupancy by Firmalan and Felipe Gaa, Sr., but later clarified Firmalan was not occupying the lot; instead, Elmer Galindez, Alicia’s son, was occupying it beside Gaa. Following ejectment attempts and dismissal by the Municipal Trial Court of Romblon—which acknowledged only the Bureau of Lands could determine rightful ownership—the Bureau’s Supervising Land Examiner Dionico F. Gabay, after hearings and ocular inspection, concluded that there was no dispute as to Gaa’s portion, but between Firmalan and Alicia, Firmalan had the superior right. He reasoned Firmalan complied with the Public Land Act’s requirements, while Alicia allegedly acquired possession through “trickery” and violation of the law.

Administrative Decisions Upholding Firmalan’s Applications

The Department of Environment and Natural Resources (DENR) Regional Executive Director, in an August 27, 1990 order, confirmed that Firmalan's 1949 application was filed prior to Alicia’s and was entitled to preference. The Regional Executive Director emphasized that long possession of public land does not ripen into ownership absent compliance with the Public Land Act’s statutory requirements. Alicia’s subsequent motions for reconsideration were denied, and the DENR Secretary affirmed these rulings in 1998, ordering Alicia to vacate the premises and forfeiting her payments.

The Office of the President, upon Alicia's appeal in 2005, similarly upheld the DENR's factual findings and rulings, dismissing Alicia’s assertions of denial of due process. Alicia’s motion for reconsideration was denied in 2006.

Judicial Review and Court of Appeals’ Affirmation

Alicia appealed to the Court of Appeals, which in November 2008 affirmed the Office of the President’s decision. The Court held that Firmalan’s earlier filing and compliance with the conditions of her application entitled her to preference. It ruled that Alicia’s long possession was not legally protected because it violated the terms of her own application and the governing land laws. Alicia’s motion for reconsideration was denied in March 2009.

Petitioner's Arguments Before the Supreme Court

Before the Supreme Court, Alicia acknowledged Firmalan’s 1949 application but argued it was disregarded because the lot was never surveyed or appraised and the ordered reappraisal was not done. She maintained her family’s continuous occupancy since 1950, including declaration for tax purposes, and insisted her 1964 application over the lot inhabited by her family should have given her preference under the Public Land Act. Alicia also contended that Firmalan and her family occupied and fenced the property after filing their application, violating its terms. She further accused Firmalan of seeking multiple lots and enjoying unlawful support from DENR officials.

Respondent's and DENR’s Position

Firmalan and the DENR underscored consistent factual findings by administrative bodies and the Court of Appeals that she complied with application requirements and that Alicia acted in bad faith by occupying the lot prematurely. The Department and administrative bodies’ findings, supported by substantial evidence, were highlighted as binding and deserving of respect.

Supreme Court's Analysis on Applicable Law and Factual Findings

The Supreme Court applied the 1936 Public Land Act (Commonwealth Act No. 141) governing the disposition of agricultural public lands at the time of the applications. It recalled that under this law, acquisition of ownership over public agricultural lands can only occur through modes expressly provided, such as sales or homestead settlement. Mere possession of public lands, regardless of duration, does not confer ownership.

The Court emphasized the conclusive effect of factual findings made by the Director of Lands, when approved by the Secretary of Agriculture and Commerce (now Environment and Natural Resources). This principle aligns with Rule 43, Section 10 of the Rules of Civil Procedure, which provides that a quasi-judicial agency’s findings of fact, when supported by substantial evidence, are binding on courts.

The Court recognized that administrative bodies, by virtue of their expertise and jurisdiction over public lands, possess technical knowledge enabling them to resolve such disputes with appropriate dispatch and specialization. Accordingly, it affirmed the administrative findings that Firmalan filed her applications first and complied with rules, while Alicia did not.

On Whether Premature Occupation Affect Application Preference

The Court rejected Alicia’s contention that her long possession should give her preferential status despite violating application term

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