Case Summary (G.R. No. L-27811)
Factual Background
Jose Magallanes occupied and used a 1,103-hectare pasture in Tamlangon, Davao, under a government permit. In 1953 he assigned to petitioner a 392.7569-hectare portion, which was reclassified for agricultural use in 1954. In early 1955, Pano and others applied for 90 ha of that area; petitioner thereafter applied for the entire tract.
Administrative Proceedings
After conflicting claims, the Director of Lands (July 31, 1956) granted petitioner’s application and rejected Pano’s. On appeal, the Secretary of Agriculture and Natural Resources (July 5, 1957) upheld that decision. Pano then escalated the dispute to the President.
Executive Secretary’s Intervention
Acting by authority of the President, Executive Secretary Juan Pajo (June 25, 1958) modified the prior rulings. He ordered that the northern portion be subdivided for actual occupants (including Pano’s group), subject to reimbursement to petitioner for survey costs.
Trial Court and Issue on Appeal
Petitioner sued in the Court of First Instance to declare the Secretary’s decision final and invalidate the Executive Secretary’s order. The trial court dismissed the suit, prompting petitioner’s appeal to the Supreme Court.
Presidential Control over Executive Departments
The Court held that the President’s constitutional duty to execute the law (Art. VII, Sec. 7) and to control executive departments (Art. VII, Sec. 10[1]) necessarily encompasses the power to review, confirm, modify, or reverse decisions of department secretaries—including lands decisions affirmed by the Secretary of Agriculture and Natural Resources.
Delegation to the Executive Secretary
The Constitution does not require the President personally to decide every appeal. By delegation (e.g., Executive Order No. 94, Sec. 27), the Executive Secretary may act with “authority of the President,” exercising the President’s power over departmental decisions.
Executive Secretary as Alter Ego of the President
When the Executive Secretary acts “by authority of the President,” his decisions are legally those of the President. Absent explicit disapproval by the President, such decisions carry full force and are not open to collateral attack.
Supreme Court’s Ruling
The petitioner's contention that Commonwealth Act No. 141, Sec. 4, renders factual findings by the Director of Lands co
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Facts
- In 1932, Jose Magallanes was a permittee and actual occupant of a 1,103-hectare pasture land in Tamlangon, Municipality of Bansalan, Province of Davao.
- On January 9, 1953, Magallanes ceded to Lacson-Magallanes Co., Inc. his rights to a 392.7569-hectare portion of that land.
- On April 13, 1954, the ceded portion was officially released from the forest zone and classified as agricultural land.
- On January 26, 1955, Jose Pano and nineteen other claimants applied to purchase 90 hectares of the released area, claiming actual occupancy and improvements.
- On March 29, 1955, the plaintiff corporation filed a sales application for the entire released tract; Pano and his companions protested, alleging prior occupancy.
- The disputed land corresponded to the northern portion of Block I, LC Map 1749, Project No. 27, Bansalan, Davao, with the Latian River as the dividing line.
Procedural History
- July 31, 1956: The Director of Lands, after investigation, granted the corporation’s application and dismissed Pano’s claim; a motion for reconsideration was denied.
- July 5, 1957: On appeal, the Secretary of Agriculture and Natural Resources affirmed the Director’s decision, dismissing Pano’s appeal as without merit.
- June 25, 1958: Acting by authority of the President, Executive Secretary Juan Pajo modified the prior decisions—ordering subdivision of the controverted land and allocation of lots to the actual occupants, subject to reimbursement of survey costs to the corporation.
- The corporation filed Special Civil Case No. 2792 in the Court of First Instance of Davao, Branch II, seeking (1) declaration that the Secretary’s decision remained in full force and (2) annulment of the Executive Secretary’s decision.
- The trial court dismissed the complaint. The Court of Appeals, under Sections 17 and 31 of the Judiciary Act of 1948 (as amended), certified the case to the Supreme Court.
Issues Presented
- May the Executive Secretary, acting by authority of the President, reverse a decision of the Direct