Barranco v. Commission on the Settlement of Land Problems
REITERATIONFacts
The Antecedents: Josefina Beliran, daughter of Crestituto Diolosa, filed letter-complaints with the Commission on the Settlement of Land Problems (COSLAP) alleging that structures built by Teresita Barranco and Paciencia Siatong encroached upon her father's property in Iloilo City. COSLAP initiated proceedings, and during mediation, Beliran and Barranco, through her attorney-in-fact, entered into an amicable settlement. The settlement stipulated that a relocation survey would be conducted, and Barranco would vacate any encroaching portion of her structure within one month of the survey's results. However, Barranco later repudiated the settlement and revoked her attorney-in-fact's authority. Procedural History: Following Barranco's repudiation, COSLAP approved the amicable settlement and issued a resolution, which Barranco moved to reconsider. After COSLAP denied her motion, Barranco filed a petition for certiorari with the Supreme Court, assailing COSLAP's jurisdiction. This petition was dismissed by the Supreme Court for late filing, and a subsequent motion for reconsideration was also denied, leading to an entry of judgment. Meanwhile, COSLAP issued a writ of execution, which was returned unsatisfied, prompting Beliran to move for a writ of demolition. COSLAP subsequently issued the writ of demolition. Barranco, Siatong, and the heirs of Julia Rodriguez then filed a special civil action for injunction and prohibition with the Regional Trial Court (RTC) of Iloilo City, seeking to stop the demolition. The RTC granted an injunction, finding COSLAP lacked jurisdiction. COSLAP appealed to the Court of Appeals, which reversed the RTC's decision, setting aside the injunction and ordering the dismissal of the case before the RTC, ruling that the RTC committed grave abuse of discretion by not dismissing the case on grounds of res judicata and forum shopping, and that trial courts cannot restrain COSLAP from executing its orders. The Petition: This petition for review on certiorari under Rule 45 of the Rules of Court assails the Court of Appeals' decision and resolution. Petitioner Teresita S. Barranco argues that the Court of Appeals erred in not ruling on the issue of COSLAP's initial jurisdiction, in setting aside the RTC's orders, and in finding that her petition before the RTC was barred by res judicata and constituted forum shopping. Specifically, Barranco contends that the dismissal of her prior Supreme Court petition was based on a technicality (late filing) and thus not a judgment on the merits, precluding res judicata. She also argues that COSLAP lacked jurisdiction because the dispute involved private property and did not fall within the enumerated cases over which COSLAP may assume jurisdiction, nor did it constitute an agrarian dispute within the jurisdiction of the DARAB.
Issue(s)
Whether the filing by petitioner of the Petition for Injunction and Prohibition before the Regional Trial Court of Iloilo City, Branch 33 and docketed as Special Civil Case No. 01-26899 is barred by res judicata considering the prior dismissal by this Court of petitioner’s petition for certiorari with prayer for a writ of preliminary injunction docketed as G.R. No. 146729. Whether petitioner is guilty of forum shopping. Whether the COSLAP has jurisdiction over the dispute between petitioner and Beliran.
Ruling
The Supreme Court granted the petition, set aside the Court of Appeals' decision and resolution, and reinstated the Regional Trial Court's October 29, 2001 Order enjoining the implementation of the writ of demolition for lack of jurisdiction. The Commission on the Settlement of Land Problems (COSLAP) was ordered to dismiss COSLAP Case No. IL-00-06-013 for lack of jurisdiction.
Ratio Decidendi
On the issue of res judicata: The Court held that res judicata does not apply because the dismissal of the prior petition (G.R. No. 146729) by the Supreme Court was based solely on the ground of late filing. For res judicata to apply, a former judgment must be final, rendered by a court with jurisdiction, be a judgment on the merits, and involve identity of parties, subject matter, and causes of action. Since the dismissal was on a technicality and not on the merits of the case, the essential requisite of a judgment on the merits was wanting. Therefore, the principle of res judicata could not be invoked to bar the subsequent filing of the petition before the RTC. On the issue of forum shopping: The Court affirmed the Court of Appeals' finding that petitioner was guilty of forum shopping. Petitioner deliberately sought another forum, the RTC, to obtain relief after her petition questioning COSLAP's jurisdiction was dismissed by the Supreme Court. Instead of awaiting the final verdict of COSLAP and appealing therefrom, she filed a petition with the RTC to enjoin the enforcement of COSLAP's writ of demolition. This action of seeking relief from multiple forums based on the same set of facts and issues constitutes forum shopping, which is a ground for dismissal. On the issue of COSLAP's jurisdiction: The Court found that COSLAP did not have jurisdiction over the dispute. COSLAP, as an administrative agency of limited jurisdiction, can only exercise powers specifically granted by its enabling statutes. Executive Order No. 561 grants COSLAP two options: refer the matter to the agency with appropriate jurisdiction or assume jurisdiction if the case is critical and explosive in nature, involving specific types of disputes related to public lands or government grants. In this case, the property in dispute was private property, and the parties were private individuals without any tenurial arrangement. The dispute was not critical or explosive, nor did it fall under the enumerated categories where COSLAP could assume jurisdiction. Therefore, COSLAP acted without jurisdiction in entertaining the complaint and issuing the writ of demolition.
Main Doctrine
A dismissal of a petition for certiorari for late filing does not constitute res judicata as it is not a judgment on the merits. However, filing a similar petition after such dismissal constitutes forum shopping. Trial courts cannot restrain quasi-judicial agencies of co-equal rank from executing their orders.