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(1)
Underlying the rulings of the trial and appellate courts is the doctrine
of primary jurisdiction; i.e., courts cannot and will not resolve a
controversy involving a question which is within the jurisdiction of an
administrative tribunal, especially where the question demands the
exercise of sound administrative discretion requiring the special
knowledge, experience and services of the administrative tribunal to
determine technical and intricate matters of fact. In recent years, it has
been the jurisprudential trend to apply this doctrine to cases involving
matters that demand the special competence of administrative agencies
even if the question involved is also judicial in character. 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 view. "In cases where the doctrine of primary jurisdiction is clearly
applicable, the court cannot arrogate unto itself the authority to resolve
a controversy, the jurisdiction over which is initially lodged with an
administrative body of special competence.
(2)
Reliance by the trial and the appellate courts on the factual findings of
the Director of Lands and the Minister of Natural Resources is not
misplaced. By reason of the special knowledge and expertise of said
administrative agencies over matters falling under their jurisdiction,
they are in a better position to pass judgment thereon; thus, their
findings of fact in that regard are generally accorded great respect, if not
finality, by the courts. The findings of fact of an administrative agency
must be respected as long as they are supported by substantial evidence,
even if such evidence might not be overwhelming or even preponderant.
It is not the task of an appellate court to weigh once more the evidence
submitted before the administrative body to substitute its own
judgment for that of the administrative agency in respect of sufficiency
of evidence. However, the rule that factual findings of an administrative
agency are accorded respect and even finality by courts admits of
exceptions. This is true also in assessing factual findings of lower courts.
It is incumbent on the petitioner to show that the resolution of the
factual issues by the administrative agency and/or by the trial court falls
under any of the exceptions Otherwise, this Court will not disturb such
findings.
The lack of technical description did not prove that the finding of the
Director of Lands lacked substantial evidence. Here, the issue is not so
much whether the subject land is identical with the property purchased
by petitioner. The issue, rather, is whether the land covered by the sales
application is private or public land. In his sales application, petitioner
expressly admitted that said property was public land. This is formidable
evidence as it amounts to an admission against interest.