Manuel v. Villena, 37 SCRA 745 (1971)

FACTS: This is an appeal from the order of the CFI of Tarlac dismissing the case entitled “Manuel v. Villena, the Director of Forest and the Secretary of ANR,” wherein the plaintiff sought the annulment of the decision of the said public official rejecting his application for a Tree Farm Permit over a 20-hectare parcel of land, which was included in a 66-hectare are covered by a similar application of private defendant Villena.

ISSUE: WON the decision of the Secretary of DENR should be set aside

RULING: Under Section 1838 of the RAC, this function falls within the jurisdiction of the Director of Forestry with the approval of the Secretary of ANR.

The power thus conferred on the Director of Forestry with the approval of the Secretary of ANR is basically executive or administrative in nature. And courts, as a rule, refuse to interfere with the proceedings undertaken by the administrative bodies or officials in the exercise of administrative functions. This is so because such bodies are generally better equipped technically to decide administrative questions and that non-legal factors, such as government policy on the matter, are usually involved in the decisions.

There are of course, limits to the exercise of administrative discretion. Administrative proceedings may be reviewed by the courts upon the showing that “the board or official has gone beyond his statutory authority, exercised unconstitutional powers or clearly acted arbitrarily and without regard to his duty or with grave abuse of discretion” or that the decision is vitiated by fraud, imposition or mistake.

Since 1838 of the RAC does not require the investigation be in the nature of a court trial. In deciding administrative questions, administrative bodies or officials generally enjoy wide discretion. Technical rule of procedure are not strictly enforced and due process of law in the strict judicial sense is not indispensable. It is sufficient that substantive due process requirement of fairness and reasonableness be observed.

Absence of previous notice is not itself a substantial defect; what the law abhors is the lack of opportunity to be heard.

It was not essential that the appellant be represented by a lawyer. The investigation conducted by Bureau of Forestry was purely fact-finding. It was not required to be in a form of a trial where both parties, each represented by a counsel, confront each other and their witnesses. In any case, appellant does not allege that the presence of a lawyer could have altered the result of the investigation. He does not even cite any substantial error in the findings of the Director of Forestry which could have been avoided, if a lawyer had represented him.

It should be noted that the order of the Acting Secretary of ANR, a formal investigation of the case was ordered. That the investigation was actually conducted was not denied, and is borne out by the decision of the Secretary dismissing the plaintiff’s appeal.

We have examined the documents and pleadings reproduced in the appellant’s record on appeal, particularly the decision of the Secretary of ANR which is sought to be set aside, and we find that the said decision is based on a thorough analysis of the facts as revealed by evidence.