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Lacson Magallanes Co. Inc. v. Paño 21 SCRA 895

This case involves a land dispute between a corporation and 19 farmers over ownership of 90 hectares of land. The Director of Deeds and Secretary of Natural Resources both ruled in favor of the corporation. However, the Executive Secretary modified this ruling, allocating the portions improved by the farmers to them. The corporation argued this was an overreach of power. However, the Supreme Court upheld the Executive Secretary's decision, finding that (1) the President has full control over subordinate decisions, (2) the Executive Secretary acts with presidential authority and can modify other officials' rulings, and (3) no presidential disapproval was shown, so the Executive Secretary's decision stands.

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126 views1 page

Lacson Magallanes Co. Inc. v. Paño 21 SCRA 895

This case involves a land dispute between a corporation and 19 farmers over ownership of 90 hectares of land. The Director of Deeds and Secretary of Natural Resources both ruled in favor of the corporation. However, the Executive Secretary modified this ruling, allocating the portions improved by the farmers to them. The corporation argued this was an overreach of power. However, the Supreme Court upheld the Executive Secretary's decision, finding that (1) the President has full control over subordinate decisions, (2) the Executive Secretary acts with presidential authority and can modify other officials' rulings, and (3) no presidential disapproval was shown, so the Executive Secretary's decision stands.

Uploaded by

Ming Yao
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Lacson-Magallanes Co., Inc. v.

Paño, 21 SCRA 895

at bar is a petition for appeal to an earlier decision of the lower courts in affirming that the executive secretary, acting by authority of the
president, modified a ruling held by the director of land that was affirmed by the exec. Secretary on natural resources

involved is a disputed land whereas the respondent and 19 other farmers are laying claim – a 90-hectare land. While the plaintiff corporation filed
a sales application of the entirety of a land which included the 90-hectare claim of the respondent farmers.

Director of deeds’ decision, affirmed by the Secretary of natural resources, held in favor of the claim of the corporation

the farmers brought the decision of the case to the Exec. Secretary for an appeal, which was modified by the latter stating that the farmer’s claim
of the lands which were subjected from their improvements be allocated to them.

Plaintiff corpo brought the decision of exec sec to the trial court = the same held that the exec. Secretary did the right thing

-plaintiff argue that the decision of the Sec. of nat’l resources is conclusive, that the exec. Secretary is barred from recognizing such
case
-…..further argues that the decision of the Exec. Secretary is an undue delegation of powers, that said powers should be exercised by
the President individually
-……further argues that exec secretary and the sec. for nat’l resources are equal in rank, that neither of them can intrude to the
allocated zone or office of each other

SC HELD

1. The president has full control over his appointed subordinate’s decision.
2. It is not an undue delegation, exec secretary is an alter-ego of the pres and such duties or powers cannot be expected of the president to
presence or individual exercise, due to the fact that the Pres has multifarious admin functions
3. It is not an encroachment on the part of the exec. Secretary, for he acts in accordance to the authority vested in him by the president.
The latter is the only one who can disapprove or reprobate such decision of the exec secretary

1. The President's duty to execute the law is of constitutional origin.3 So, too, is his control of all executive departments.4 Thus it is, that
department heads are men of his confidence. His is the power to appoint them; his, too, is the privilege to dismiss them at pleasure.
Naturally, he controls and directs their acts. Implicit then is his authority to go over, confirm, modify or reverse the action taken by his
department secretaries.

Parenthetically, it may be stated that the right to appeal to the President reposes upon the President's power of control over the
executive departments.8 And control simply means "the power of an officer to alter or modify or nullify or set aside what a subordinate
officer had done in the performance of his duties and to substitute the judgment of the former for that of the latter."

2. The President is not expected to perform in person all the multifarious executive and administrative functions. The Office of the
Executive Secretary is an auxiliary unit which assists the President. The rule which has thus gained recognition is that "under our
constitutional setup the Executive Secretary who acts for and in behalf and by authority of the President has an undisputed jurisdiction
to affirm, modify, or even reverse any order" that the Secretary of Agriculture and Natural Resources, including the Director of Lands,
may issue.

3. the Executive Secretary acts "[b]y authority of the President," his decision is that of the President's. Such decision is to be given full
faith and credit by our courts. The assumed authority of the Executive Secretary is to be accepted. For, only the President may
rightfully say that the Executive Secretary is not authorized to do so. Therefore, unless the action taken is "disapproved or reprobated
by the Chief Executive,"13 that remains the act of the Chief Executive, and cannot be successfully assailed.14 No such disapproval or
reprobation is even intimated in the record of this case.

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