Manubay v. Garilao
REITERATIONFacts
The Antecedents: This case concerns a 124-hectare agricultural land in Pili, Camarines Sur, owned by petitioners Annie L. Manubay and others, and Manubay Agro-Industrial Development Corp. The core dispute arose when the Municipal Agrarian Reform Officer (MARO) issued a notice of coverage on November 15, 1994, placing the property under the Comprehensive Agrarian Reform Program (CARP). Subsequently, on August 26, 1996, the Sangguniang Bayan of Pili passed Resolution No. 145, approving a zoning ordinance that reclassified the subject property from agricultural to highly urbanized, intended for mixed residential and commercial use. Procedural History: Following the notice of coverage, the petitioners did not initially protest. Instead, on July 1, 1996, they filed an application with the Department of Agrarian Reform (DAR) for the conversion of the property. DAR Regional Director Percival C. Dalugdug denied their request, citing DAR Administrative Order No. 12, s. 1994, which prohibits accepting conversion applications for lands already issued notices of coverage. Respondent Ernesto Garilao, then DAR Secretary, upheld this denial. Petitioners' subsequent motions for reconsideration were also denied. Aggrieved, they filed a petition for certiorari with the Court of Appeals (CA), arguing that the DAR Secretary acted with grave abuse of discretion. The CA dismissed their petition, finding that the Office of the President (OP) was the more competent body to rule on the issue and that petitioners had failed to exhaust available administrative remedies. The Petition: Petitioners seek review of the CA's resolution dismissing their petition for certiorari. They contend that the CA erred in ruling that they failed to exhaust administrative remedies, arguing that the act of a department secretary can be directly challenged via certiorari. Petitioners maintain that the issuance of a mere notice of coverage, as opposed to a notice of acquisition, should not have been a ground for denying their conversion application. They argue that the DAR Secretary committed grave abuse of discretion by denying their application based on the notice of coverage, especially after the land had been reclassified by local ordinance.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari on the ground of failure to exhaust administrative remedies. Whether the respondent Secretary acted with grave abuse of discretion in denying petitioners' application for conversion.
Ruling
The Supreme Court dismissed the petition. It affirmed the resolutions of the Court of Appeals dated June 1, 1999, and November 4, 1999, in CA-G.R. SP No. 47244.
Ratio Decidendi
On the issue of failure to exhaust administrative remedies: The Court reiterated the doctrine of qualified political agency, wherein department secretaries are considered alter egos of the President, and their acts are presumed to be those of the President unless disapproved. However, this doctrine does not negate the rule on exhaustion of administrative remedies. Section 1 of Rule 65 of the Rules of Court requires that for a petition for certiorari to prosper, there must be no appeal or a plain, speedy, and adequate remedy in the ordinary course of law. In this case, DAR Administrative Order No. 7, s. 1997, explicitly provides that the decision of the DAR Secretary on applications for conversion may be appealed to the Office of the President. This appeal to the OP constituted the plain, speedy, and adequate remedy contemplated by law. By failing to pursue this administrative remedy, the petitioners' resort to a petition for certiorari was premature, and the CA correctly dismissed their petition on this ground. The principle of exhaustion of administrative remedies mandates that a party aggrieved by an order of an administrative official must first appeal to the higher administrative authority before seeking judicial relief; otherwise, the complaint will be dismissed for being premature. On the issue of grave abuse of discretion: The Court found that the respondent Secretary did not commit grave abuse of discretion. The denial of the petitioners' application for conversion was based on a valid ground, which was that the property had already been issued a notice of coverage under the CARP. DAR Administrative Order No. 12, s. 1994, clearly states that no application for conversion shall be accepted on lands for compulsory acquisition already given notices of coverage, unless such notices are lifted. Since the petitioners failed to have the notice of coverage lifted, the DAR Secretary acted within his authority and discretion when he denied their application. The reclassification of the land by the Sangguniang Bayan did not automatically render the notice of coverage invalid or ineffective for the purpose of CARP coverage. Therefore, the respondent's action was not arbitrary, despotic, or an evasion of a duty enjoined by law, which are the hallmarks of grave abuse of discretion.
Main Doctrine
A petition for certiorari assailing the denial of an application for land conversion by the Secretary of the Department of Agrarian Reform (DAR) must first exhaust the administrative remedies by appealing to the Office of the President, as provided by DAR Administrative Order No. 7, s. 1997, before resorting to judicial action. Failure to do so renders the petition premature.