Dulay v.

Minister of Natural Resources (1993)

Doctrine:
It is already well-settled in jurisprudence that the decisions and orders of administrative
agencies rendered pursuant to their quasi-judicial authority, have, upon their finality, the force
and binding effect of a final judgment within the purview of the doctrine of res judicata. The rule
of res judicata which forbids the reopening of a matter once judicially determined by competent
authority applies as well to the judicial and quasi-judicial acts of public, executive or
administrative officers and boards acting within their jurisdiction.

Summary:
This case involves a petition by Dulay asking the SC to confine the Director of BFAR within his
jurisdiction and to uphold the principle of res judicata by nullifying his orders giving due course
to Dico’s request to re-open the two DANR cases which had longed attained finality and his
telegrams stating the dismissal of her MRs. Dico, on the other hand, contended that res judicata
does not apply in cases where the government has to exercise its inherent power to regulate.
The SC ruled in favor of Dulay, stating that the DANR cases, for not having been brought to the
courts for judicial review, had become final and executor. Therefore, the Director of BFAR
abused his discretion in insisting on the continuation of the formal investigation on the basis of
res judicata.

Issues:
W/N res judicata applies in this case. YES. As such, the Court made permanent the TRO.

Ruling:
The rule of res judicata which forbids the reopening of a matter once judicially determined by
competent authority applies as well to the judicial and quasi-judicial acts of public, executive or
administrative officers and boards acting within their jurisdiction.

The first case was already dismissed by the OP. Since the same was not brought to the courts for
judicial review, the same has become final and executory.

The second case regarding the same free patent application was also rejected by the Director of
Lands. Since this was also not brought before the courts for judicial review, the same has
become final and executory.

The matter having become final, it was grave abuse of discretion on the part of public
respondent Director of the Bureau of Fisheries and Aquatic Resources to give due course to
private-respondent's letter-petition of October 28, 1977 requesting for a re-opening of the
fishpond conflict involved herein.