Lacuesta v Herrera Facts: Petitioner Amado Lacuesta was declared a partner over one-half of a fishpond by the Court of First Instance of Davao. The court refused to act on the prayer for partition as the fishpond was considered part of public lands. Lacuesta filed an application with the Philippine Fisheries Commission for one-half of the fishpond, but it was denied. On appeal, the Secretary of Natural Resources ruled in favor of Lacuesta, a decision that was affirmed by the Office of the President. The respondent judge annulled the administrative decisions through a petition for certiorari and injunction. Issue: Whether the administrative decisions should be interfered with by the courts. Ruling: The Supreme Court ruled that administrative decisions are entitled to great weight and respect and should not be interfered with unless there is evidence of fraud, collusion, arbitrariness, illegality, imposition, mistake, or a lack of substantial evidence. The Court found no such evidence and granted the petition, annulling the injunction order and writ. Ratio: Administrative decisions are not to be interfered with by the courts unless there is evidence of wrongdoing or a lack of substantial evidence. The Secretary of Agriculture and Natural Resources has jurisdiction over public lands, including fishponds, and the courts have no jurisdiction over such lands. Jurisdiction over the subject matter is indispensable for a valid decision. 2 Evangelista v Jarencio Facts: Petitioner Amado Lacuesta was declared a partner over one-half of a fishpond by the Court of First Instance of Davao. The court refused to act on the prayer for partition as the fishpond was considered part of public lands. Lacuesta filed an application with the Philippine Fisheries Commission for one-half of the fishpond, but it was denied. On appeal, the Secretary of Natural Resources ruled in favor of Lacuesta, a decision that was affirmed by the Office of the President. The respondent judge annulled the administrative decisions through a petition for certiorari and injunction. Issue: Whether the administrative decisions should be interfered with by the courts. Ruling: The Supreme Court ruled that administrative decisions are entitled to great weight and respect and should not be interfered with unless there is evidence of fraud, collusion, arbitrariness, illegality, imposition, mistake, or a lack of substantial evidence. The Court found no such evidence and granted the petition, annulling the injunction order and writ. Ratio: Administrative decisions are not to be interfered with by the courts unless there is evidence of wrongdoing or a lack of substantial evidence. The Secretary of Agriculture and Natural Resources has jurisdiction over public lands, including fishponds, and the courts have no jurisdiction over such lands. Jurisdiction over the subject matter is indispensable for a valid decision. 3. Austin Hardware v CA Facts: Petitioners: Austin Hardware Company, Inc. and All Steel Products, Inc. Respondents: Court of Appeals, Elenita H. Manzano, and Francisco Inocencio Municipal Mayor of San Juan, Rizal cancelled the license and/or permit of the petitioners to engage in the manufacture of hardware and steel products at a specific address. Complaints were filed by residents in the area, claiming that the operation of these manufacturing enterprises was a nuisance to them. Petitioners filed an action for injunction in the Court of First Instance of Rizal, arguing that the revocation of their licenses violated procedural due process. Court issued a restraining order to prevent the Mayor from implementing the revocation and stopping the construction of a warehouse. Respondents filed a petition for certiorari and prohibition in the Court of Appeals, challenging the proceedings in the lower court. Court of Appeals issued a writ of preliminary injunction, enjoining the respondent judge from continuing with the proceedings and the private respondents from continuing the construction of a commercial house and maintaining a hardware business and a factory for the manufacture of steel products in the vicinity. Respondents filed a petition to cite the petitioners for contempt, which was granted by the Court of Appeals. The petitioners were fined P500. Issue: Whether or not the Court of Appeals acted within its jurisdiction in enjoining the respondent judge from continuing with the proceedings and in declaring the petitioners in contempt for disregarding the order. Ruling: The Supreme Court upheld the findings of fact of the Court of Appeals and dismissed the petition. The municipality has the power to revoke licenses and permits for businesses that violate zoning ordinances. The petitioners' business establishments were situated within a residential zone, in violation of the municipality's zoning ordinance. The municipal mayor had the authority to cancel or revoke their business permits. The purpose of zoning is to protect public safety, health, convenience, and welfare. Allowing a manufacturing business in a residential zone would be inconsistent with this purpose. The petitioners had not complied with the injunction issued by the Court of Appeals, as evidenced by the findings of the Deputy Clerk of Court during an investigation. The Court upheld the contempt ruling and the fine imposed on the petitioners. 4. Manuel vs Villena Facts: Magno Manuel filed a complaint seeking the annulment of a decision rejecting his application for a Tree Farm Permit. The decision was made by the Director of Forestry and the Secretary of the Department of Agriculture and Natural Resources. Manuel alleged a violation of his right to due process. Manuel claimed continuous possession of the land since 1939 and filed his application in 1954. The Director of Forestry rejected his application because a prior application had been filed by Mariano Villena. Manuel filed two motions for reconsideration, both of which were denied. Manuel appealed to the Secretary of Agriculture and Natural Resources, but his appeal was also dismissed. Manuel argued that the Secretary's decision was made before the completion of a reinvestigation that he had ordered. Issue: Whether the administrative decision rejecting Manuel's application for a Tree Farm Permit violated his right to due process. Ruling: The court affirmed the dismissal of the complaint. The court held that the administrative decision was not subject to judicial review unless there was a grave abuse of discretion amounting to a denial of due process. The court found that Manuel was given due process as he had the opportunity to be heard and file motions for reconsideration. The court also found that the investigation conducted by the Bureau of Forestry was not required to be in the form of a trial and that the presence of a lawyer was not essential. The court concluded that Manuel failed to show any substantial error in the findings of the Director of Forestry that could have been avoided if a lawyer had represented him. Therefore, the court ruled that there was no violation of due process or grave abuse of discretion. Ratio: Administrative proceedings are generally not subject to judicial review unless there is a grave abuse of discretion amounting to a denial of due process. Administrative bodies or officials are better equipped to decide administrative questions and non-legal factors, such as government policy, are usually involved in their decisions. Technical rules of procedure are not strictly enforced in administrative proceedings and due process of law in the strict judicial sense is not indispensable. It is sufficient that the substantive due process requirement of fairness and reasonableness be observed. The presence of a lawyer is not essential in administrative investigations. The lack of previous notice is not a substantial defect as long as the opportunity to be heard is not denied. Manuel failed to show any violation of due process or grave abuse of discretion in the administrative decision. 5. Compaña General v board of piblic utiltiy Facts: The case involves a foreign corporation, Compañia General de Tabacos de Filipinas, organized under the laws of Spain. The corporation is engaged in business in the Philippine Islands as a common carrier of passengers and merchandise by water. The Board of Public Utility Commissioners issued an order requiring the corporation to file a detailed report of its finances and operations. The corporation challenged the authority of the board to require such a report. Issue: Whether the Board of Public Utility Commissioners has the authority to require a detailed report of finances and operations from a public utility company. Ruling: The court ruled in favor of the corporation. The court deemed the Act delegating legislative powers to the board as unconstitutional. The court set aside the order of the board and instructed them to dismiss the proceeding. Ratio: The court held that the provisions conferring authority on the board were too general and comprehensive. The statute gave the board the power to require a detailed report of finances and operations without specifying the nature of the report, its contents, or the principles upon which it should be based. The court stated that a statute that authorizes a board to require detailed reports without providing any guidance or direction is not expressing the will of the State or indicating what information the State requires. The court concluded that the Legislature had delegated its powers to the board in an almost absolute manner, without providing any rules or guidelines for the exercise of that power. Therefore, the court found the Act to be in violation of the Constitution. 6.
