De Leon vs Heirs of Reyes, GR No. L-74687, 12 November 1987, 155 SCRA 584

De Leon vs Heirs of Reyes

GR No. L-74687, 12 November 1987

155 SCRA 584

FACTS

            The land in question is the subject of two separate applications, one for sale filed by Gregorio Reyes and one for free patent filed by petitioner Antonio De Leon. Both are based on the claim of actual possession.

            The Bureau of Lands ruled against Reyes, who appealed to the Ministry of Natural Resources. The Assistant Secretary for Legal Affairs set aside the decision of the Bureau, but was reversed by the Minister on motion for reconsideration. Private respondents elevated the case to the Office of the President where they were sustained.

ISSUE

            Whether or not the challenged decision was issued with grave abuse of discretion.

HELD

            The Court held in the affirmative. While there is no disputing the authority of administrative superiors to reverse the findings of their subordinates, this power must be exercised sparingly and only upon a clear showing of error. Lacking such flaw, the decision of the lower administrative officials should be sustained, if only because they have closer access to the problem sought to be resolved and have the direct opportunity to question the parties and their witnesses and to assess the evidence first-hand.