Case Summary (G.R. No. L-30637)
Concession Boundaries and Encroachment Reports
• Both concessions share the Agusan–Surigao provincial boundary: Lianga’s western limit and Ago’s eastern limit.
• Descriptions rely on distances, bearings and designated “corners” along roads and creeks.
• Reports of mutual encroachment prompted the Director of Forestry to commission a survey to locate the true common boundary.
Decision of the Director of Forestry
• Survey by Forester Melchor relocated Corner 5 to Km 10.2 on the Los Arcos–Lianga Road and prescribed bearings and distances.
• Ago protested, invoking the statutory provincial boundary as per Act 1693.
• The Director held that:
– Ago’s line conflicted with original license-map distances (6,800 m vs. 13,800 m projection).
– Acceptance of Ago’s claim would distort licensed areas.
– Distances and bearings control when “imaginary” boundary lines exist on official maps.
• The Director fixed the common boundary per his red-pencil sketch.
Appeals to the Secretary of Agriculture and Office of the President
• Ago appealed to Acting Secretary Feliciano (DANR Case No. 2268); on August 9, 1965 he adopted Ago’s green-line boundary.
• Lianga elevated to the Office of the President:
– June 16, 1966 – Assistant Executive Secretary Leido affirmed the Feliciano ruling.
– August 9, 1968 – Assistant Executive Secretary Duavit reversed the Acting Secretary’s decision and reinstated the Director’s original boundary.
• Ago’s motion for reconsideration was denied October 2, 1968 by Assistant Executive Secretary Leido.
Civil Case No. 1253 and Injunctive Relief
• October 21, 1968 – Ago filed Civil Case No. 1253 in CFI Agusan seeking judicial determination of the boundary, damages, and a preliminary injunction.
• October 28–29, 1968 – The trial court issued a TRO and then a writ of preliminary injunction enjoining enforcement of the Office of the President’s decision.
• December 19, 1968 – The court denied Lianga’s motion to dismiss and granted the preliminary injunction.
• May 9, 1969 – Motion for reconsideration was denied by the trial judge.
Petition for Certiorari and Prohibition
• Lianga petitioned the Supreme Court to:
a. Declare the Director of Forestry’s exclusive jurisdiction over the boundary.
b. Affirm the Office of the President’s August 9, 1968 decision as final and executory.
c. Dismiss Civil Case No. 1253.
d. Annul the trial court’s restraining order and injunction.
• June 30, 1969 – Supreme Court issued a restraining order against enforcement of the trial court’s injunctive writ.
Jurisdiction of Administrative Agencies
• Rev. Adm. Code § 1816 vests the Bureau of Forestry with exclusive authority over forest boundaries, licensing, and management.
• Rev. Adm. Code § 79(c) authorizes the Secretary of Agriculture and Natural Resources to modify the Director’s rulings.
• Executive Order No. 19 (1966) allows appeal to the Office of the President.
• License terms (Ordinary Timber License No. 1323-60 [New]) confirm the Director’s boundary determination as final and binding.
Limits on Judicial Interference
• Courts may not reassess evidence already weighed by specialized administrative bodies absent grave abuse of discretion.
• Administrative findings are binding unless the agency exceeded statutory authority, acted unconstitutionally, arbitrarily, or with grave abuse of discretion.
• Precedents (Espinosa v. Makalintal; Pajo v. Ago) reinforce non-interference with purely administrative, discretionary decisions.
Provisions on Administrative and Injunctive Powers
• Rule 65, Sec. 4 (Rules of Court) limits CFI injunctive po
Case Syllabus (G.R. No. L-30637)
Facts of the Case
- Petitioner Lianga Bay Logging Co., Inc. (Lianga) holds Timber License Agreement No. 49 covering approximately 110,406 hectares in Surigao Province.
- Respondent Ago Timber Corporation (Ago) holds Ordinary Timber License No. 1323-60 [New] covering approximately 4,000 hectares in Agusan Province, formerly part of a 9,000-hectare concession under Ordinary Timber License No. 584-’52.
- The two concessions are adjacent, sharing the Agusan–Surigao provincial boundary as the contested common line.
- Divergent boundary descriptions arise from distance-and-bearing controls on license maps versus reliance on the statutory provincial boundary under Act 1693.
- A field survey by Forester Melchor fixed the common boundary differently from Ago’s claimed “green line,” prompting administrative protests.
Administrative Proceedings
- The Director of Forestry (March 20, 1961) upheld the survey’s red-pencil boundary, emphasizing distance and bearing over an “imaginary” statutory line.
- Ago appealed to the Acting Secretary of Agriculture and Natural Resources (DANR Case No. 2268), which on August 9, 1965 reversed the Director’s decision and adopted the green line.
- Petitioner elevated the matter to the Office of the President: Assistant Executive Secretary Leido affirmed the Director’s red-line ruling on June 16, 1966.
- On motion for reconsideration, Assistant Executive Secretary Duavit (August 9, 1968) reversed Leido’s decision, reinstating the Director of Forestry’s original ruling.
- Ago’s motion for reconsideration of the Duavit decision was denied by Assistant Executive Secretary Leido on October 2, 1968—thus rendering the Director of Forestry’s red-line boundary final and executory.
Judicial Proceedings Below
- On October 21, 1968, Ago filed Civil Case No. 1253 in the Court of First Instance (CFI) of Agusan, Branch II, naming Lianga and the involved public officials as defendants, seeking judicial determination of the boundary and