Case Digest (G.R. No. 168990)
Facts:
The case involves Teresita S. Barranco as the petitioner and the Commission on the Settlement of Land Problems (COSLAP) as the respondent. The events leading to this case began on April 26, 2000, when Josefina Beliran, the daughter of Crestituto Diolosa, filed two handwritten complaints against Barranco and Paciencia Siatong, alleging that their structures encroached on her father's property located at Corner Compania and San Juan, Molo, Iloilo City. COSLAP, a government entity under the Department of Justice created by Executive Order No. 561, issued summons to the parties involved. Barranco filed a motion to dismiss the complaint, claiming lack of jurisdiction, which was denied by COSLAP.
During a mediation conference on June 2, 2000, an amicable settlement was reached, stipulating that a relocation survey would be conducted to determine property boundaries. However, Barranco repudiated this settlement on June 15, 2000, and revoked the Special Power of Attorney grant...
Case Digest (G.R. No. 168990)
Facts:
- Creation and Purpose of COSLAP: The Commission on the Settlement of Land Problems (COSLAP) was created under Executive Order No. 561 to provide an effective mechanism for the expeditious settlement of land disputes, particularly those involving settlers, landowners, and cultural minorities.
- Complaint by Josefina Beliran: On April 26, 2000, Josefina Beliran filed two handwritten complaints with COSLAP against Teresita Barranco and Paciencia Siatong, alleging that their structures encroached on her father’s property in Iloilo City.
- Amicable Settlement: During a mediation conference on June 2, 2000, Beliran and Barranco (through her attorney-in-fact) entered into an Amicable Settlement, agreeing to a relocation survey. Barranco later repudiated the settlement and revoked her attorney-in-fact’s authority.
- COSLAP’s Resolution and Writ of Demolition: COSLAP approved the Amicable Settlement and issued a Writ of Demolition after the survey confirmed that Barranco’s structure encroached on Beliran’s property.
- Barranco’s Legal Actions: Barranco filed a Petition for Certiorari with the Supreme Court, which was dismissed for late filing. She then filed a Petition for Injunction and Prohibition with the Regional Trial Court (RTC) of Iloilo City, which granted a temporary restraining order against COSLAP’s writ of demolition.
- Court of Appeals Decision: The Court of Appeals reversed the RTC’s decision, ruling that Barranco was guilty of forum shopping and that COSLAP’s orders were valid.
Issue:
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Ruling:
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Ratio:
- Res Judicata: For res judicata to apply, the judgment must be on the merits. Since the Supreme Court dismissed Barranco’s earlier petition for late filing, it was not a judgment on the merits, and thus, res judicata does not apply.
- Forum Shopping: Barranco’s filing of a similar petition in the RTC after the Supreme Court’s dismissal constituted forum shopping, as she sought another forum to obtain relief after failing in the first attempt.
- Jurisdiction of COSLAP: COSLAP’s jurisdiction is limited to disputes involving public lands, squatters, or cultural minorities. Since the dispute involved private land and did not meet the criteria for COSLAP’s jurisdiction, its actions were null and void.
Conclusion:
The Supreme Court granted Barranco’s petition, set aside the Court of Appeals’ decision, and reinstated the RTC’s order enjoining COSLAP from implementing the writ of demolition. COSLAP was ordered to dismiss the case for lack of jurisdiction.