Republic v. Damayan ng Purok 14, Inc.
REITERATIONFacts
1. The Antecedents: Respondent Damayan ng Purok 14, Inc., a corporation composed of residents of Signal Village, Taguig, Metro Manila, claimed ownership over a 10,600 square meter area within Lot 1, SWO-13-00258, in Barangay Signal Village. This land was part of a larger tract segregated from Fort Bonifacio and declared open for disposition by Presidential proclamation. Petitioner, represented by the Armed Forces of the Philippines Housing Administration (AFPHA), asserted that this area was government land intended for its housing projects. 2. Procedural History: Respondent filed a complaint with the Commission on the Settlement of Land Problems (COSLAP). COSLAP issued a resolution declaring approximately 98,207 square meters of the contested lot as part of Barangay Signal Village and generally unavailable for government projects. Petitioner's motion for reconsideration was denied by COSLAP. Subsequently, petitioner filed a petition for review with the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure. The Court of Appeals dismissed this petition, deeming it the wrong mode of appeal, as COSLAP's resolutions were allegedly appealable only to the Supreme Court via certiorari. 3. The Petition: Petitioner seeks review of the Court of Appeals' decision and resolution, which dismissed its petition for being the wrong remedy. The sole issue presented to the Supreme Court is the correct appellate court for decisions rendered by COSLAP. Petitioner argues that its appeal to the Court of Appeals under Rule 43 was the appropriate procedural step, contrary to the appellate court's ruling that such appeals must go directly to the Supreme Court via certiorari as stipulated in Executive Order No. 561.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for review filed by the Republic of the Philippines. What is the proper mode of appeal from the resolutions of the Commission on the Settlement of Land Problems (COSLAP)?
Ruling
The petition is GRANTED. The decision of the Court of Appeals dated March 14, 2000, and its resolution dated May 9, 2000, are SET ASIDE. The Court of Appeals is ordered to take cognizance of the petition for review filed by petitioner Republic of the Philippines for resolution without further delay.
Ratio Decidendi
On the Court of Appeals' dismissal of the petition: The Supreme Court ruled that the Court of Appeals erred in dismissing the petition for review filed by the Republic of the Philippines. The Court held that the petitioner properly brought its petition to the Court of Appeals seeking a review of a resolution of COSLAP, which is a quasi-judicial agency. Consequently, the CA's decision and resolution denying the motion for reconsideration were set aside, and the CA was ordered to take cognizance of the petition. On the proper mode of appeal from COSLAP resolutions: The Supreme Court clarified that appeals from the orders, resolutions, or decisions of COSLAP shall be taken to the Court of Appeals in accordance with Rule 43 of the 1997 Rules of Civil Procedure. The Court noted that the provision in Section 3(2) of Executive Order No. 561, which declared COSLAP's decisions appealable exclusively to the Supreme Court, was erroneous in light of Sections 1, Rule 45 and 1, Rule 43 of the 1997 Rules of Civil Procedure. The Court emphasized that, as with other administrative agencies discharging quasi-judicial functions, recourse must first be had through the Court of Appeals. This transfer of appellate jurisdiction to the Court of Appeals is procedural and remedial, not substantive, and does not impair vested rights as a remedy and a competent tribunal remain available. Therefore, the Court of Appeals erred in dismissing the petition for review filed by the petitioner on the ground that it was the wrong mode of appeal. The petitioner correctly brought its petition to the Court of Appeals as COSLAP is a quasi-judicial agency.
Main Doctrine
Appeals from resolutions of the Commission on the Settlement of Land Problems (COSLAP) shall be taken to the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure, not directly to the Supreme Court.