5. Villaflor vs.

Court of Appeals It applies "where a claim is originally cognizable in the courts, and comes into play whenever enforcement of the claim requires the resolution of issues which, under a regulatory scheme, have been placed within the special competence of an administrative body; in such case, the judicial process is suspended pending referral of such issues to the administrative body for its review." Petition for Review on Certiorari Panganiban, J.: The controversy is concerning parcels of public land under contest between Vicente Villaflor and Nasipit Lumber. Their relatioinship began when Villaflor leased said parcels to Nasipit (despite the investigator of lands reporting that he had no transmissible rights over said parcels) before selling them to the latter. Said parcels, unfortunately, were still public lands and both parties had to bid at a public option for a government grant to own them. Villaflor was the preferred bidder and matched Nasipits bid. He, however, had pressing mat ters to attend to and changed his residence to Manila, inducing him to creat a deed relinquishing his rights in Nasipits favor in exchange for money. Consequently, the Director of Lands awarded the parcels to the corporation. After ten years in Indonesia, however, Villaflor wanted his land back. He died during the whole process by the way, just thought you should know. He claimed: a. Lands were his private property. b. He did not know of the grant: Order of Award, and the Bureau of Lands and all the othe r courts ignored this. c. Deed of Relinquishment was not paid for. d. Corporations could not own land because of the 1973 Constitution. ISSUE and ANSWER: Petition is bereft of merit. Did the CA err in adopting or relying on the factual findings of the Bureau of Lands, the Minister of Natural Resources and the trial Court? Doctrine of Primary Jurisdiction dictates that they did not. The court must respect the findings of an administrative agency as long as they are supported by substantial evidence. It is not the task of an appellate court to weigh once more the evidence submitted before the administrative body and Villaflors evidence held very little credibility. Did the CA err in upholding the validity of the contracts to sell and the deed of relinquishment? No they did not. Villaflor argued that there was a simulation of contracts, totally misunderstanding what simulation of contracts meant. Parties to the contract were clear in their intents. No simulation was proven. Is the private respondent qualified to acquire title over the disputed property? Nasipit is qualified. Public land was acquired before 1973. Villaflor had already relinquished his rights in favor of Nasipit.