Bagunu v. Aggabao

G.R. No. 186487 (August 15, 2011)

Supreme Court upheld DENR's rejection of Bagunu's claim to Lot 322 in favor of Aggabao spouses.

Facts:

The case revolves around a dispute over a parcel of unregistered land located in Caniogan, Sto. Tomas, Isabela, which was the subject of a free patent application filed by Rosito Bagunu (petitioner). The land was previously owned by Marcos Binag, who sold it to Felicisimo Bautista, and later to Atty. Samson Binag. Atty. Binag applied for a free patent over the land in 1961 and subsequently sold it to the petitioner in 1987, with the deed of sale indicating the land as Lot 322.

In 1992, spouses Francisco Aggabao and Rosenda Acerit (respondents) filed a protest against the petitioner's free patent application, claiming ownership of Lot 322 based on deeds of extrajudicial settlement with sale executed in their favor by the heirs of Rafael Bautista. The Department of Environment and Natural Resources (DENR) conducted an ocular inspection and found that the petitioner occupied and cultivated the disputed area, which included the land claimed by the respondents.

On July 10, 1998, the DENR ruled that the petitioner wrongfully included Lot 322 in his application, ordering him to amend his application to exclude Lot 322 and allowing the respondents to file their own application for the same lot. The petitioner’s motion for reconsideration was denied, leading to an appeal to the DENR Secretary, who affirmed the ruling of the DENR Regional Office.

The petitioner then appealed to the Court of Appeals (CA), which upheld the DENR Secretary's decision. Meanwhile, a civil case for reformation of instruments was filed by Atty. Binag against the petitioner and Bautista, which was joined by the respondents through a complaint-in-intervention, seeking to quiet title and recover damages.

Legal Issues:

  1. Whether the DENR had jurisdiction to resolve the conflicting claims of ownership over Lot 322, given that the issue was also pending before the Regional Trial Court (RTC).
  2. Whether the application of the doctrine of primary jurisdiction was appropriate in this case.

Arguments:

  • Petitioner’s Arguments:

    • The petitioner contended that the CA erred in affirming the DENR Secretary's jurisdiction, arguing that the issue of ownership and the identity of the land involved interpretation of contracts and appreciation of evidence, which are within the competence of the courts.
    • He asserted that the DENR's findings were contrary to the evidence, claiming that the deed of sale clearly identified the property as Lot 322 and that he had been in possession of the land since 1987.
    • The petitioner also questioned the sufficiency of the respondents' evidence to prove their ownership.

  • Respondents’ Arguments:

    • The respondents maintained that they had valid claims over Lot 322 based on their deeds of extrajudicial settlement and that the DENR's findings supported their ownership.
    • They argued that the DENR had the authority to resolve the issue of land identity, which required technical expertise.

Court’s Decision and Legal Reasoning:

The Supreme Court denied the petitioner’s motion for reconsideration, affirming the CA's ruling. The Court held that the determination of the identity of public land falls within the exclusive jurisdiction of the DENR, which is tasked with managing and disposing of public lands. The Court emphasized that the issue of land identity requires technical determination, which is the province of the DENR and not the courts.

The Court reiterated the doctrine of primary jurisdiction, stating that when a matter requires the specialized knowledge and expertise of an administrative agency, the courts must defer to the agency's determination before proceeding with judicial review. The Court found that the DENR's exclusion of Lot 322 from the petitioner’s application and the directive for the respondents to apply for a free patent were within the DENR Secretary's administrative discretion.

Significant Legal Principles Established:

  1. Primary Jurisdiction Doctrine: Courts must defer to the jurisdiction of administrative agencies when the resolution of a controversy requires specialized knowledge and expertise that the agency possesses.
  2. Exclusive Jurisdiction of DENR: The DENR has exclusive jurisdiction over the management and disposition of public lands, including resolving conflicting claims of ownership over such lands.
  3. Technical Determination of Land Identity: The identity of public land and its boundaries is a factual issue that requires technical determination by the appropriate administrative body.