G.R. No. L-21066; April 30, 1965
MARIA A. GAYACAO, petitioner-appellant, vs. THE HON. EXECUTIVE SECRETARY OF THE PRESIDENT OF THE PHILIPPINES, HON. SECRETARY OF AGRICULTURE AND NATURAL RESOURCES, THE DIRECTOR OF LANDS and FELIXBERTO ALCARMEN, respondents-appellees.

FACTS

On January 2, 1962, petitioner-appellant Maria A. Gayacao filed a complaint in the Court of First Instance of Basilan City against the Executive Secretary, the Secretary of Agriculture and Natural Resources, the Director of Lands, and private respondent Felixberto Alcarmen. She alleged that on April 3, 1935, she acquired the right to purchase residential Lots Nos. 55 and 56 in Isabela, Basilan City, through Miscellaneous Sales Application No. 8558, which was received by the Bureau of Lands. She paid the due installments, and the Bureau recommended approval of her application on October 24, 1939. She improved the lots, paid taxes, and remained in possession. After World War II, Alcarmen, a war refugee, secured her permission to temporarily occupy part of the lots but later filed his own Miscellaneous Sales Application No. V-8113 over Lot 55. In 1949, the Director of Lands, without hearing Gayacao and despite her prior rights, gave due course to Alcarmen’s application and excluded Lot 55 from her application. The respondent secretaries affirmed this decision on appeal. Gayacao sought judicial review and annulment of the administrative decision, alleging violations of Section 81 of Commonwealth Act No. 141 and improper retroactive application of Lands Administrative Order No. 7-1. She prayed for the annulment or amendment of the decision to grant her Lot No. 55, due course to her application, rejection of Alcarmen’s application, and a declaration that Alcarmen’s improvements were made in bad faith.
The respondent public officials moved to dismiss, contending that the Court of First Instance of Basilan City lacked jurisdiction to entertain petitions for writs of certiorari or mandamus or to issue such writs against officers holding office outside its territorial jurisdiction, invoking Section 44(h) of the Judiciary Act and Supreme Court rulings in Acosta vs. Alvendia and Samar Mining Co. vs. Arnado. The lower court granted the motion and dismissed the petition on December 3, 1962. Gayacao appealed directly to the Supreme Court.

ISSUE

Whether the Court of First Instance of Basilan City has jurisdiction to review and annul an administrative decision rendered by national officials (the Director of Lands, the Secretary of Agriculture and Natural Resources, and the Executive Secretary) whose offices are located outside its territorial jurisdiction.

RULING

Yes. The Supreme Court reversed the order of dismissal and remanded the case to the lower court for further proceedings.
The Court held that the lower court erred in dismissing the petition for lack of jurisdiction. A careful analysis of the petition showed that Gayacao’s principal complaint was a judicial review of the administrative decision, seeking its annulment based on alleged errors of law (violation of Section 81 of Commonwealth Act No. 141 and improper retroactive application of Lands Administrative Order No. 7-1). This power of judicial review arises from the doctrine of supremacy of law, which lodges in the courts the inherent authority to decide the constitutionality of legislative enactments and the exercise of delegated powers, and to enforce constitutional rights, such as the guaranty against deprivation of property without due process.
The doctrines invoked by the respondents (Castaño vs. Lobingier, Acosta vs. Alvendia, Samar Mining Co. vs. Arnado) were inapplicable because those cases involved petitions for writs of injunction seeking to control the actions of courts or officers outside the territorial jurisdiction of the respondent courts. In contrast, the sole issue here was the legal correctness of the administrative decision. The Court saw no cogent reason why this power of judicial review should be confined to courts of first instance where the offices of the respondents are maintained, to the exclusion of courts where the plaintiffs reside and where the questioned decisions are being enforced.
Sustaining the lower court’s ruling would result in hardship to litigants of limited means, practically amounting to denial of access to the courts, and would unnecessarily encumber Manila courts with already over-burdened dockets. The Court noted that since Ortua vs. Singson, the power of provincial courts of first instance to review administrative decisions of national officials has been consistently recognized.
While Gayacao also prayed for ancillary relief (e.g., reinstatement of her application), such remedy was purely corollary to the main relief sought, as reversal of the administrative decision would necessarily lead to the same result.