Summarized

YSMAEL
The case revolves around Ysmael, Jr. & Co., Inc. (hereafter referred to as "petitioner"), a company
involved in timber operations in the Philippines. The events in question occurred in the wake of the
change in government in February 1986. Following this change, petitioner sought reinstatement of its
timber license agreement (TLA), which had been cancelled during the Marcos administration, as well
as the revocation of another TLA issued to Twin Peaks Development and Realty Corporation without
public bidding, and permission to take possession of logs in the concession area. Petitioner alleged
that it had a valid TLA (No. 87) dating back to 1965, but in 1983, the Bureau of Forest Development,
under instructions from the President, cancelled logging operations in certain provinces, including
where petitioner operated. Despite attempts to appeal, no favorable action was taken. Furthermore,
petitioner claimed that a significant portion of its former concession area was re-awarded to Twin
Peaks Development and Realty Corporation without proper process. It also alleged connections
between the new concessionaires and the ousted Marcos regime.
The Ministry of Natural Resources (MNR), through then Minister Ernesto Maceda, denied petitioner's
requests, citing a ban on logging operations in certain provinces for conservation and national
security reasons. The Ministry emphasized its role as a trustee of forest resources and its obligation to
ensure their availability for future generations.
Petitioner's subsequent motions for reconsideration were also denied. The administrative ban on
logging in the relevant province was eventually lifted. Petitioner appealed to the Office of the
President, which also ruled against it, citing lack of merit and premature filing.
Issue: Whether or not Ysmael, Jr. & Co., Inc. (petitioner) should be granted relief through a writ of
certiorari to overturn administrative decisions regarding its timber license agreement (TLA) and the
allocation of logging concessions
The court ruled against Ysmael, Jr. & Co., Inc. (petitioner), denying its request for relief through a writ
of certiorari to overturn the administrative decisions regarding its timber license agreement (TLA) and
the allocation of logging concessions.
Finality of Administrative Decisions: The court emphasized that decisions of administrative

agencies, once final and executory, carry the force of final judgments and are binding on the parties
involved, similar to the doctrine of res judicata. In this case, petitioner failed to challenge the
administrative actions in a timely manner, thereby precluding any reconsideration by the court.
Failure to File within Reasonable Period: The court noted that petitioner failed to file the petition
within a reasonable period, leading to the application of the doctrine of laches. The delay in seeking
judicial recourse undermined petitioner's claims.
Public Policy Considerations: The court acknowledges the importance of public policy
considerations, particularly in matters concerning the development and conservation of natural
resources. It recognizes ongoing efforts by the government to reassess and evaluate timber license
agreements and permits issued under previous administrations in response to global concerns over
deforestation and ecological balance. While the court expressed concern over alleged irregularities in
the issuance of TLAs, it found no evidence of grave abuse of discretion by the respondents in this
case.
Presumption of Regularity in Administrative Actions: The court upheld the presumption of

regularity in the actions of government agencies, emphasizing that the burden of proof lies with the
petitioner to demonstrate grave abuse of discretion. Without sufficient evidence of wrongdoing, the
court declined to interfere with the administrative decisions.
Importance of Environmental Conservation: The court underscored the importance of

environmental conservation and sustainable development, indicating that the government's actions
were guided by public policy objectives aimed at preserving forest resources for future generations.
Mustang Lumber Inc. vs. CA, Factoran, GR. No. 104988
Two cases, G.R. No. 104988 and G.R. No. 123784, were initially assigned to separate divisions of the
Court but were consolidated with a third case by the Court en banc. The petitioner, Mustang Lumber,
Inc., had its lumber-dealer's permit suspended and subsequently faced confiscation of its lumberyard
stock due to alleged violations. The case involved actions by the Department of Environment and
Natural Resources (DENR) against Mustang Lumber, including the seizure of lumber and legal
proceedings.
On April 1, 1990, the DENR team conducted surveillance and seized a truck loaded with lumber from
Mustang Lumber's lumberyard, citing lack of proper documentation. Subsequent seizures followed on
April 3 and 4, 1990, resulting in administrative seizure of lumber from the lumberyard. Despite
requests for extension and claims of having acquired required documents, Mustang Lumber failed to
provide them.
As a response to the actions of the DENR, Mustang Lumber filed two petitions for certiorari and
prohibition against the DENR officials involved. The first case (Civil Case No. 90-53648) challenged the
legality of the seizures and subsequent orders of confiscation. The second case (Civil Case No. 90-
54610) challenged another incident of seizure at Mustang Lumber's business premises. Additionally,
the president and general manager of Mustang Lumber faced criminal charges for illegal possession
of lumber.
The trial court dismissed the criminal case against Mustang Lumber's president and general manager,
ruling that possession of lumber without legal documents is not a crime under existing laws.
However, the Court of Appeals upheld the trial court's decision, stating that despite the absence of
specific mention of lumber in the relevant law, possession of lumber without proper documentation
falls within the purview of the law.
Whether the seizure of lumber and the actions taken by the Department of Environment and Natural
Resources (DENR) in enforcing forestry laws is valid
The decision was appealed to the Supreme Court, which affirmed the Court of Appeals' decision,
stating that possession of lumber without proper documentation constitutes an offense under
existing laws. The Supreme Court further clarified that while the law did not specifically mention
lumber, it falls under the category of timber, as lumber is a processed form of timber or logs.
Therefore, possession of lumber without proper documentation is punishable under the law.
G.R. No. 104988:
 The petitioner failed to demonstrate any reversible error committed by the Court of Appeals.
 The seizure of the petitioner's truck and cargo loaded with lumber without proper documents
was deemed valid under Section 80 of P.D. No. 705.
 The search conducted on April 3, 1990, was lawful as it was on a moving vehicle, falling under
one of the exceptions to the requirement of a search warrant.
 The search conducted on April 4, 1990, was a continuation of the previous day's search and
thus permissible.
 The argument that possession of lumber without legal documents is not illegal was dismissed
based on a previous ruling (G.R. No. 106424).
G.R. No. 123784:
 The Court of Appeals decision to dismiss the petitioner's appeal from the trial court's judgment
was affirmed.
 The suspension of the petitioner's lumber-dealer's license was not disputed, and thus, the
petitioner had no right to possess or dispose of lumber.
 The seizure of lumber by the Department Head or his authorized representative was deemed
lawful under Section 68-A of P.D. No. 705.
 The argument that possession or sale of lumber is not penalized was rejected based on a
previous ruling (G.R. No. 106424).
In conclusion, G.R. No. 104988 was denied, while G.R. No. 123784 was dismissed. The court
emphasized the importance of enforcing forestry laws and protecting the environment.

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YSMAEL

Finality of Administrative Decisions: The court emphasized that decisions of administrative

Presumption of Regularity in Administrative Actions: The court upheld the presumption of

Importance of Environmental Conservation: The court underscored the importance of

G.R. No. 104988:

G.R. No. 123784:

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