United Residents of Dominican Hill, Inc. v. Commission on the Settlement of Land Problems
REITERATIONFacts
The Antecedents: The case involves a dispute over a 10.36-hectare property in Baguio City known as Dominican Hills. The property, formerly owned by Diplomat Hills, Inc., was mortgaged to UCPB, foreclosed, and then donated to the Republic of the Philippines by UCPB. Executive Order No. 85 transferred assets of the Ministry of Human Settlements to the Presidential Management Staff (PMS). Petitioner, UNITED RESIDENTS OF DOMINICAN HILL, INC. (UNITED), applied to acquire a portion of the property. A Memorandum of Agreement was signed among PMS, HOME INSURANCE GUARANTY CORPORATION (HIGC), and UNITED, stipulating that PMS would sell to HIGC, which would then sell to UNITED at P75.00 per square meter. HIGC sold 2.48 hectares to UNITED, and after UNITED's final payment, HIGC executed a Deed of Absolute Sale. Procedural History: Petitioner alleges that private respondents entered and constructed houses on the portion allocated to UNITED. After UNITED secured a demolition order, private respondents, under the name DOMINICAN HILL BAGUIO RESIDENTS HOMELESS ASSOCIATION (ASSOCIATION), filed an action for injunction (Civil Case No. 3316-R) in the RTC of Baguio City, obtaining a temporary restraining order, but their prayer for a preliminary injunction was denied. While Civil Case No. 3316-R was pending, the ASSOCIATION, represented by Land Reform Beneficiaries Association, Inc. (BENEFICIARIES), filed another case (Civil Case No. 3382-R) for damages, injunction, and annulment of the Memorandum of Agreement between UNITED and HIGC. This second case was dismissed by the RTC, an order which is currently on appeal. Demolition orders were implemented, but private respondents allegedly returned and reconstructed their structures. To prevent re-implementation, private respondents filed a petition for annulment of contracts with a prayer for a temporary restraining order before the Commission on the Settlement of Land Problems (COSLAP) on September 29, 1998, docketed as COSLAP Case No. 98-253. On the same day, COSLAP issued a status quo order. The Petition: Petitioner filed the instant petition for prohibition and declaratory relief seeking the annulment of the status quo order issued by COSLAP, questioning COSLAP's jurisdiction and alleging forum shopping by private respondents.
Issue(s)
Whether the Commission on the Settlement of Land Problems (COSLAP) is empowered to hear and try a petition for annulment of contracts and issue a status quo order. Whether the private respondents engaged in forum shopping.
Ruling
The petition is GRANTED. The status quo order dated September 29, 1998, issued in COSLAP Case No. 98-253 by respondent Commission on the Settlement of Land Problems (COSLAP) is SET ASIDE; and the petition filed in COSLAP Case No. 98-253 and the complaint in Civil Case No. 3316-R are DISMISSED for lack of jurisdiction and forum shopping. Costs against private respondents.
Ratio Decidendi
On the Jurisdiction of COSLAP: The Court held that COSLAP, while possessing quasi-judicial functions, is an administrative agency and not a court. Its jurisdiction, as defined by Executive Order No. 561, is primarily to coordinate and resolve land problems, with the power to assume jurisdiction over critical and explosive cases. However, the Court clarified that COSLAP may not assume jurisdiction over cases already pending in the regular courts. The phrase "force and effect of a regular administrative resolution, order or decision" emphasizes its administrative character, binding on other administrative or executive agencies, not the judiciary. The Court's role is to determine if there has been grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government, including COSLAP. Therefore, COSLAP was not justified in assuming jurisdiction over a controversy already being litigated in the regular courts. On Forum Shopping: The Court found that private respondents engaged in forum shopping. Forum shopping is defined as the repetitive availment of several judicial remedies in different courts, simultaneously or successively, founded on the same transactions and essential facts, raising substantially the same issues. The Court noted several transgressions by the private respondents: failure to submit a certification against forum shopping in the COSLAP petition, failure to notify the RTC branches of pending cases, filing a false certification in Civil Case No. 3382-R by not mentioning the pendency of Civil Case No. 3316-R, and the apparent lack of notification to the trial courts about the COSLAP case. The Court emphasized that the willful attempt to obtain injunctive relief in multiple forums after failing in one constitutes grave abuse of the judicial process. The private respondents' actions mocked attempts to eradicate forum shopping and upset the orderly administration of justice, warranting the summary dismissal of the actions filed.
Main Doctrine
The Commission on the Settlement of Land Problems (COSLAP) may not assume jurisdiction over cases already pending in the regular courts, and its status quo orders are subject to review for grave abuse of discretion amounting to lack or excess of jurisdiction. Furthermore, engaging in forum shopping warrants the dismissal of the petitions filed.