Tuesday, June 20, 2017

Case Digest: Felipe Ysmael, etc vs. Deputy Executive Secretary, etc

G.R. No. 79538
Felipe Ysmael, etc vs. Deputy Executive Secretary, etc
October 18, 1990


Petitioner sought the reconsideration of a memorandum order issued by the Bureau of Forest Development which cancelled its timber license agreement in 1983, as well as the revocation of TLA No. 356 subsequently issued by the Bureau to private respondents in 1984 by sending letters to the Office of the President and the MNR [now the Department of Environment and Natural Resources (DENR). Petitioner’s prayers were to no avail. Hence the petition in the Court, imputing grave abuse of discretion to public respondents.

RULING:

The Court stressed the authority of administrative bodies to handle matters within there scope without need of interference by the courts of law. These administrative bodies are deemed to be in better positions to determine issues within their specialty and resolve the same. The Court cited the doctrine of res judicata which avers that the decisions and orders of administrative agencies have upon their finality, the force and binding effect of a final judgment. The rule of res judicata thus forbids the reopening of a matter once determined by competent authority acting within their exclusive jurisdiction


The Court also held that the assailed orders by public respondent was in line with the latter’s duty to develop and conserve the country’s natural resources in view of the constitutional mandate of the right of the people to a balanced and healthful ecology in accord with the rhythm and harmony of nature. It is their duty to regulate the issuance of licenses (TLA) as they see fit, which the court cannot interfere with. The Court further held that sans grave abuse of discretion which may be imputed to public respondents, the court ruled that petitioner cannot seek affirmative relief.

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