Facts:

This case involves a land dispute between Guillermo Banaga, the heirs of Jose C. Toledo (specifically Biblia Toledo, Josefin Toledo, and Concepcion Vda. de Toledo) as petitioners, and the Commission on the Settlement of Land Problems (COSLAP) and Gregorio Daproza, Sr. as respondents. The dispute dates back to September 1961, when Daproza learned that Natividad Anguis was selling a 30-hectare property located in Bo. Calutansahig, Makar, General Santos City. Due to financial constraints, Daproza entered into a verbal agreement with Jose Toledo, where the latter would purchase the land and later sell half of it to Daproza upon reimbursement.

Toledo officially acquired the land through a Deed of Sale on January 18, 1962. Daproza made an initial payment of P1,650.00 towards the agreed total price of P3,200.00 for his share. Toledo proceeded to survey the property and made a lot plan that received approval from the Director of Lands. However, unbeknownst to Daproza, Toledo later sold

...

Facts:

Background of the Dispute

• The case involves a petition for certiorari under Rule 65 seeking the annulment of the decision rendered by the Commission on the Settlement of Land Problems (COSLAP) on September 2, 1983.
• The dispute centers on conflicting free patent applications and claims over a parcel of public land originally involving a verbal agreement between Jose C. Toledo and Gregorio Daproza, Sr.

Parties Involved

• Petitioners: Guillermo Banaga and the heirs of Jose C. Toledo (namely, Biblia Toledo, Josefina Toledo, and Concepcion, widow of Toledo).
• Respondents: Gregorio Daproza, Sr., whose claim is based on a verbal agreement with Jose Toledo regarding the acquisition of a portion of the disputed land.

Transaction and Initial Agreements

• In September 1961, Gregorio Daproza, Sr. learned that Natividad Anguis was selling a 30-hectare land parcel in Bo. Calutansahig, Makar, General Santos City.
• Unable to purchase the entire lot, Daproza entered into a verbal agreement with his relative and friend, Jose Toledo, whereby Toledo would pay for the whole lot and subsequently convey one-half of the area to Daproza upon reimbursement of the purchase price.
• A Deed of Sale was executed on January 18, 1962, in favor of Jose Toledo by the seller, Natividad Anguis.
• On April 7, 1963, Daproza paid an initial amount of P1,650.00 to Toledo as part of the agreed consideration for one-half the area of the lot.

Land Surveys, Free Patent Applications, and Conflicting Claims

• Toledo, without informing Daproza, caused the survey of the entire lot leading to the issuance of survey plan Psu-206571, which subdivided the land into three lots.
• On January 8, 1965, petitioner Banaga (Toledo’s son-in-law) filed a free patent application (No. 37-875) with the Bureau of Lands over Lot 1 of Psu-206571, and on February 8, 1965, Toledo conveyed Lot 1 to Banaga for P5,000.00.
• Daproza filed his own free patent application (No. (VIII-4) 3584) for Lots 2 and 3—corresponding to the same physical area disputed by Banaga’s application.
• Toledo did not oppose Daproza’s application initially, and later, his daughter, Biblia Toledo Banaga, filed a formal protest on December 31, 1971.
• Despite the various protests and conflicting claims, no investigation was undertaken by the Bureau of Lands for an extended period.

Administrative Proceedings and the Role of PACLAP/COSLAP

• On June 6, 1972, Daproza formally requested that the Provincial Committee of the Presidential Action Committee on Land Problems (PACLAP) in South Cotabato investigate the conflicting claims, leading to its docketing as PPC Case No. 7213.
• During the proceedings, petitioners (Banaga and Toledo) questioned the jurisdiction of the PACLAP, contending that the Director of Lands was already authorized to investigate.
• After hearings on the issue of jurisdiction and the merits of the conflicting claims, the PACLAP Provincial Committee in Koronadal, South Cotabato, issued a resolution on September 20, 1978, which:
• Recognized the existence and partial execution of the verbal agreement between Toledo and Daproza.
• Directed the amendment of survey plans and free patent applications to reflect the parties’ respective interests.
• Ordered the dismissal of the protest filed by Toledo (through his representative, Biblia Toledo Banaga) regarding Daproza’s free patent application.
• Determined a monetary adjustment to prevent unjust enrichment.
• Petitioners appealed this resolution on several grounds, including alleged jurisdictional overreach by the PACLAP Provincial Committee.
• Executive Order No. 561, issued on September 21, 1979, abolished PACLAP and established COSLAP, which on September 2, 1983, rendered a decision affirming the PACLAP resolution.
• A motion for reconsideration was filed by the petitioners on the COSLAP decision and subsequently denied, prompting the present petition for certiorari.

Petitioners’ Contentions

• Petitioners argue that the Provincial PACLAP in Koronadal lacked jurisdiction over the dispute, asserting that it should reside with the Bureau of Lands.
• They dispute the validity and enforceability of the alleged verbal contract between Toledo and Daproza, contending that any action to enforce it is barred by the statute of limitations.
• Additionally, they allege that the administrative bodies (both PACLAP and its successor, COSLAP) erroneously assumed jurisdiction over matters properly within the province of the civil courts.

Summary of the Judicial Proceedings

• The Supreme Court evaluated the jurisdiction of the administrative bodies, the proper application of the laws (including Executive Orders and Presidential Decrees), and the principle of estoppel in preventing parties from assuming inconsistent positions.
• Ultimately, the petition was dismissed for lack of merit, and the COSLAP decision affirming the PACLAP resolution was sustained.

Issue:

Jurisdiction of Administrative Bodies

• Whether the Provincial PACLAP (and by its succession, COSLAP) had the requisite jurisdiction to hear and decide the conflicting claims over public land disputed between the parties.
• Whether the administrative body’s decision should be confounded with the jurisdiction of the Bureau of Lands, as argued by the petitioners.

Validity and Enforceability of the Verbal Agreement

• Whether a verbal agreement between Jose Toledo and Gregorio Daproza, Sr. for the sale of one-half of the land is valid and enforceable.
• Whether any action to enforce such a verbal agreement is barred by the statute of limitations.

Interpretation of Administrative Provisions

• Whether the PACLAP resolution properly resolved the conflicting free patent applications and protests in accordance with the powers conferred by Executive Orders No. 251, No. 305, and Presidential Decree No. 832.
• Whether the reference by the Provincial PACLAP to issues involving distinct and independent transactions was appropriate in light of the evidence (res ipsa loquitur).

Estoppel and Inconsistent Posturing

• Whether petitioners are estopped from now challenging the jurisdiction of the PACLAP/COSLAP given that they did not raise such jurisdictional issues in earlier proceedings.
• Whether it is proper for a party to shift its stance on jurisdiction after having accepted previous administrative decisions favorable to its claims.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)