Вы находитесь на странице: 1из 2

VILLAFLOR v CA & NASIPIT LUMBER CO.

 Having 'made some sort of agreement for the occupancy (of the property at
Rule 133 Section 5 – Substantial Evidence | Oct. 9, 1997 | J. Panganiban Acacia, San Mateo), but I no longer recall the details and I had forgotten
whether or not we did occupy your land. But if, as you say, we did occupy it,
Nature of Case: Petition for review on certiorari then (he is) sure that the company is obligated to pay the rental.'
Digest maker: IT  Jan. 16, 1974: After his arrival to the Philippines, coming from Indonesia, where he
DOCTRINE: The findings of fact of an administrative agency must be respected as stayed for more than ten (10) years, Villaflor went to Butuan City and learned that
long as they are supported by substantial evidence. Even if such evidence might not Nasipit Lumber had failed and refused to pay the agreed rentals
be overwhelming or even preponderant. It is not the task of an appellate court to weigh  Although his brother was able to collect during the early years
once more the evidence submitted before the administrative body and to substitute its  Jan. 31, 1974: Villaflor filed a formal protest with the Bureau of Lands, wherein he
own judgment for that of the administrative agency in respect of sufficiency of protested the Sales Application of Nasipit Lumber
evidence.  Claimed that the company has not paid him P5,000.00 as provided in the Deed
of Relinquishment of Rights dated August 16, 1950.
FACTS:  Aug. 8, 1977: The Director of Lands made the ff. findings:
 Nov. 8, 1946: Villaflor, in a Lease Agreement. leased to Nasipit Lumber Co., Inc. a  That payment of the amount of P5,000.00 in the Deed of Relinquishment, and
parcel of land, containing an area of two (2) hectares the consideration in the Agreement to Sell were duly proven
 July 7, 1948: In an 'Agreement to Sell”, Villaflor conveyed to Nasipit Lumber, two (2)  Ordered the dismissal of Villaflor's protest
parcels of land  Gave due course to the Sales Application of Nasipit Lumber
 The parties agreed that Nasipit Lumber shall continue to occupy the property  That Villaflor’s Sales application in 1948 was rejected for leasing the same to
not anymore in concept of lessee, but as prospective owners another even before he had acquired transmissible rights thereto
 Dec. 2, 1948: Villaflor filed Sales Application No. V-807 8 with the Bureau of Lands,  That Villaflor recognized the public character of the land in his Sales
Manila, 'to purchase under the provisions of Chapter V, XI or IX of Commonwealth Application and via the Deed of Relinquishment of Rights, he relinquished any
Act. No. 141 (The Public Lands Act), as amended, a tract of public lands and all rights he may have by virtue of continuous occupation and cultivation
 Dec. 7 1948, Villaflor and Nasipit Lumber executed an “Agreement,” confirming the thereon
Agreement to Sell, but with reference to the Sales Application filed with the Bureau of  From the decision of the Director of Lands, Villaflor filed a Motion for Reconsideration
Land which was considered as an Appeal M.N.R. Case 4341, to the Ministry of Natural
 Dec. 31, 1949: In a report by the public land inspector, District Land Office, Bureau of Resources.
Lands, in Butuan, there was an Indorsement of the aforesaid District Land Officer  July 6, 1978: Villaflor filed a complaint in the TC for "Declaration of Nullity of Contract
recommending rejection of the Sales Application of Villaflor (Deed of Relinquishment of Rights), Recovery of Possession (of two parcels of land
 For having leased the property to another even before he had acquired subject of the contract), and Damages"
transmissible rights thereto  June 6, 1979: The Minister of Natural Resources rendered a Decision,
 January 23, 1950: In a letter by Villaflor, addressed to the Bureau of Lands, he dismissing the appeal and affirming the decision of the Director of Lands
informed the Bureau Director that he was already occupying the property when the  Villaflor appealed the decision of the Minister of Natural Resources to the Office
Bureau's Agusan River Valley Subdivision Project was inaugurated of the President
 The property was formerly claimed as private property  Jan. 28, 1983: Villaflor died
 Therefore, the property was segregated or excluded from disposition because  The TC ordered his widow, Lourdes D. Villaflor, to be substituted as petitioner.
of the claim of private ownership  After trial in due course, the TC dismissed the complaint on the grounds that:
 July 24, 1950: On the scheduled date of auction of the property covered by the Sales  (1) petitioner admitted the due execution and genuineness of the contract and
Application, Nasipit Lumber offered the highest bid of P41.00 per hectare was estopped from proving its nullity,
 But since an applicant under CA 141, is allowed to equal the bid of the highest  (2) the verbal lease agreements were unenforceable under Article 1403 (2)(e)
bidder, Villaflor tendered an equal bid, deposited the equivalent of 10% of the of the Civil Code, and
bid price and then paid the assessment in full.  (3) his causes of action were barred by extinctive prescription and/or laches.
 August 1950: Villaflor executed a document, denominated as a “Deed of  The heirs of Villaflor appealed to Respondent Court of Appeals
Relinquishment of Rights,” in favor on Nasipit Lumber, in consideration of the amount  September 27, 1990: CA, however, rendered judgment against Villaflor via the
of P5,000 assailed Decision dated finding petitioner's prayers to be without basis
 This is in light of Villaflor’s difficulty to develop the land, as he has moved to  Dec. 7, 1990: Villaflor's heirs filed the instant 57-page petition for review with the SC
Manila  Assailed the findings of the Bureau of Lands and the capacity of corporations to
 On the same day, pursuant to said Deed, Nasipit Lumber filed a Sales acquire public lands
Application over the 2 parcels of land.  June 23, 1991: SC denied this petition "for being late."
 Aug. 17, 1950: “Order of Award” was then issued in favor of Nasipit Lumber.  On reconsideration — upon plea of counsel that petitioners were "poor" and that a
 November 27, 1973: Villaflor wrote a letter to Mr. G.E.C. Mears of Nasipit Lumber full decision on the merits should be rendered — the Court reinstated the petition
 Reminding him of their verbal agreement in 1955, in connection with the Deed
of Relinquishment of Rights (i.e. payment of P5K) ISSUE/S & RATIO:
 Dec. 3, 1973: Nasipit’s field manager, replied in a letter, and stated recalling:
1. W/N the CA erred in adopting or relying on the factual findings of the Bureau of  The issue, rather, is whether the land covered by the sales application is
Lands, especially those affirmed by the Minister (now Secretary) of Natural private or public land.
Resources and the trial court – NO o In his sales application, petitioner expressly admitted that said
 Reliance by the trial and the appellate courts on the factual findings of the property was public land.
Director of Lands and the Minister of Natural Resources is not misplaced o This is formidable evidence as it amounts to an admission against
 In the exercise of his primary jurisdiction over the issue, Director of Lands interest.
Casanova found that the land covered by the Sales Application was public  Clearly, the issue falls under the primary jurisdiction of the Director of Lands
 Such finding was affirmed by the Minister of Natural Resources because its resolution requires "survey, classification, . . . disposition and
 By reason of the special knowledge and expertise of said administrative agencies management of the lands of the public domain."
over matters falling under their jurisdiction, they are in a better position to pass  It follows that his rulings deserve great respect.
judgment thereon  CONCLUSION: As petitioner failed to show that this factual finding (i.e. that the
 Thus, their findings of fact in that regard are generally accorded great land in question is public) of the Director of Lands was unsupported by substantial
respect, if not finality, by the courts evidence, it assumes finality.
 GENERAL RULE: The findings of fact of an administrative agency must be  Thus, both the trial and the appellate courts correctly relied on such
respected as long as they are supported by substantial evidence finding. We can do no less.
 Even if such evidence might not be overwhelming or even preponderant
 It is not the task of an appellate court to weigh once more the evidence RULING: All in all, petitioner has not provided us sufficient reason to disturb the cogent
submitted before the administrative body and to substitute its own findings of the Director of Lands, the Minister of Natural Resources, the trial court and the
judgment for that of the administrative agency in respect of sufficiency of Court of Appeals.
evidence. WHEREFORE, the petition is hereby DISMISSED.
 EXCEPTION: However, the rule that factual findings of an administrative agency
are accorded respect and even finality by courts admits of exceptions.
 This is true also in assessing factual findings of lower courts
 It is incumbent on the petitioner to show that the resolution of the factual
issues by the administrative agency and/or by the trial court falls under
any of the exceptions.
 Otherwise, this Court will not disturb such findings
APPLICATION: In the case at bar, the resolution of factual issues by the administrative
agency DOES NOT fall under any of the exceptions
 The SC mentioned and quoted extensively from the rulings of the Bureau of
Lands and the Minister of Natural Resources because the points, questions and
issues raised by petitioner before the trial court, the appellate court and now
before this Court are basically the same as those brought up before the aforesaid
specialized administrative agencies.
 As held by the CA, the SC finds that:
 The contentious points raised by appellant in this action, are substantially
the same matters he raised in Bureau of Lands Claim No. 873 (N).
 In both actions, he:
o Claimed private ownership over the land in question,
o Assailed the validity and effectiveness of the Deed of Relinquishment
of Rights he executed in August 16, 1950
o Claimed that he had not been paid the P5,000.00 consideration, the
value of the improvements he introduced on the land and other
expenses incurred by him
 In this instance, both the principle of primary jurisdiction of administrative
agencies and the doctrine of finality of factual findings of the trial courts,
particularly when affirmed by the Court of Appeals as in this case, militate against
petitioner's cause.
 Indeed, petitioner has not given us sufficient reason to deviate from them.
 The lack of technical description did not prove that the finding of the Director of
Lands lacked substantial evidence
 Here, the issue is not so much whether the subject land is identical with
the property purchased by petitioner.

Вам также может понравиться