Juliana Etorma, et al.

vs Lucila Ravelo and the Director of Public Lands

March 24, 1947

GR. No. L-718

Facts:

Petitioner filed a certiorari assailing the validiity of the judgement of the Court of Appeals which
affirmed the decision of the lower courts against the petitioners, on the ground that the
judgement rendered by the Court of Appeals during the Japanese occupation was null and
void, because the question involved in the litigation was the validity of the a free patent issued
by the Governor General of the Philippines. The petitioners argue that since the authority to
grant free patent was conferred upon the Governor General and is the power to regulate the
procedure to obtain it upon the Legislature of the Philippines by Act of Congress makes the
decision of a political nature. Consequently, the petitioner argues, this would make the affirmed
decision of the Court of Appeals as null and void since during the Japanese occupation, the
Philippines was in a de facto government.

Issue: Whether the validity of the free patent is of a political nature

Held:

No, the fact that the question involved was the validity of a free patent, and the Director of
Public Lands was a party, and that the authority to grant free patent was conferred upon the
Governor General, and the power to regulate the procedure to obtain it upon the Legislature of
the Philippines by Act of Congress of July 1, 1902, did not make the judgement rendered
thereon of political nature. The Acts authorizing and regulating the grant of free patents to
occupants or possessors of public lands are municipal laws, and the judgement of the courts
which apply said laws are not of political complexion. Thus, the resolution upholds the Hague
Convention which contain generally accepted principles of International Law, adopted as part
of the Law of Nation which states that the judicial acts which are NOT of political complexion
are valid and binding.