Celendro v. Court of Appeals
REITERATIONFacts
The Antecedents: Private respondent is the surviving spouse of Florencio Guevarra, the awardee of Lot No. 725 PLS, containing 7.7594 hectares. Petitioner arrived in 1963 and occupied two hectares of the property with the private respondent's tolerance, under the condition that it would be returned upon demand. After the death of private respondent's husband in 1975, private respondent began demanding the return of the property. A formal demand was made on March 15, 1992, which remained unheeded, leading to an unlawful detainer case filed by private respondent before the Municipal Circuit Trial Court (MCTC) of Wao, Lanao del Sur. Procedural History: The MCTC denied a motion for referral to the DAR, finding no landlord-tenant relationship and that the lot was no longer part of a resettlement area. The MCTC rendered a decision in favor of the plaintiff (private respondent), ordering the defendant (petitioner) to vacate the portion of land and pay rent. The Regional Trial Court (RTC) affirmed the MCTC decision. A writ of execution was issued. Subsequently, private respondent filed a "Petition to Quiet Title" before the Provincial Adjudication Board (PAAB), which rendered a decision in favor of private respondent. Private respondent questioned this decision before the Department of Agrarian Reform Adjudication Board (DARAB), which affirmed the PAAB's decision. Private respondent's motion for reconsideration was denied. The Court of Appeals (CA) nullified the DARAB decision, ordering petitioner to vacate the land and restore possession to private respondent. Petitioner then filed a petition for review on certiorari before the Supreme Court. The Petition: Petitioner assails the CA decision, arguing that the civil courts (MCTC and RTC) or the DAR Adjudication Board have jurisdiction over the subject matter. Petitioner claims the land is covered by a Certificate of Land Ownership Award (CLOA) and is not part of respondent's property, thus falling under the primary jurisdiction of the Department of Agrarian Reform (DAR).
Issue(s)
Whether the civil courts (MCTC and RTC) or the DAR Adjudication Board has jurisdiction over the subject matter, considering the finality of court decisions. Whether the petitioner, having actively participated in and invoked the jurisdiction of the civil courts, can subsequently challenge that jurisdiction before an administrative body.
Ruling
The petition is devoid of merit. The assailed Decision of the Court of Appeals is affirmed. Costs against petitioner.
Ratio Decidendi
On the jurisdiction of the DAR and the finality of court decisions: The Supreme Court affirmed the Court of Appeals' ruling that an administrative body, such as the DARAB, cannot review or reverse a final and executory decision of a court. The Court emphasized that under the doctrine of conclusiveness of judgment (or collateral estoppel), issues actually and directly resolved in a former suit cannot be raised again. The MCTC's decision, affirmed by the RTC and not appealed further, had become final and executory, vesting a right in the prevailing party that could not be arbitrarily deprived. The Court reiterated that a final judgment is immutable and unalterable, and it cannot be modified directly or indirectly by any court, much less by a quasi-judicial administrative body. This principle is rooted in the separation of powers, requiring mutual respect between the branches of government, with the DARAB's jurisdiction limited to agrarian reform matters and not extending to reviewing judicial findings. On the petitioner's active participation and subsequent challenge to jurisdiction: The Court found that the petitioner actively participated in the proceedings before the MCTC and even appealed to the RTC, without questioning their jurisdiction. Having affirmed and invoked the jurisdiction of the regular courts to secure an affirmative relief, the petitioner cannot subsequently deny that same jurisdiction. This principle prevents parties from forum shopping or challenging jurisdiction only after an unfavorable decision is rendered. The petitioner's proper recourse should have been to appeal the RTC decision to the CA and, if necessary, to the Supreme Court, rather than filing a new remedy with an administrative board after the court's decision had become final.
Main Doctrine
An administrative agency has no authority to review the decisions, let alone final decisions, of courts. The remedy of a losing litigant is to appeal to the proper court, not to file a petition before a quasi-judicial body.