Case Digest (G.R. No. 137489)
Facts:
In late 1997, the Cooperative Development Authority (CDA) received complaints from members of Dolefil Agrarian Reform Beneficiaries Cooperative, Inc. (DARBCI) in Polomolok, South Cotabato, alleging mismanagement and fund misappropriation by incumbent officers, including Esmeraldo Dublin, Alicia Savarez, and Edna Ureta. On December 8, 1997, CDA Executive Director Verzosa directed the respondents to file their answers, and a week later Administrator Zingapan froze DARBCI’s funds and appointed a management committee. Before filing an answer, the private respondents sought certiorari in RTC Polomolok (SP Civil Case No. 25) challenging CDA’s jurisdiction and freeze order; the RTC issued a TRO, later suspended by the Court of Appeals (12th Division). On May 26, 1998, CDA ordered a special general assembly and election of a new board for June 14, 1998. The private respondents filed a petition for prohibition in CA (13th Div., CA-G.R. SP No. 47933) and obtained a TRO; Investa Land CorpoCase Digest (G.R. No. 137489)
Facts:
- Parties and Subject Matter
- Petitioner Cooperative Development Authority (CDA) – a government agency created under Republic Act No. 6939 to promote cooperatives.
- Respondents Dolefil Agrarian Reform Beneficiaries Cooperative, Inc. (DARBCI) and its ousted officers – alleged mismanagement of 8,860 hectares of land in Polomolok, South Cotabato.
- CDA Administrative Proceedings (CDA-CO Case No. 97-011)
- Late 1997 – CDA received complaints of fund misappropriation against DARBCI officers; Executive Director Verzosa ordered answers (Dec. 8, 1997).
- CDA Administrator Zingapan froze DARBCI funds and formed a management committee (Dec. 15, 1997).
- CDA Chairman Medina placed private respondents under preventive suspension (Feb. 24, 1998); management committee took over on March 10, 1998.
- CDA Administrator Lozada scheduled a special general assembly and elections for June 14, 1998 (May 26, 1998).
- Parallel Judicial Actions
- SP Civil Case No. 25 (RTC Polomolok) – private respondents filed certiorari with prayer for injunction (Dec. 18, 1997), secured TRO restoring status quo (Mar. 27 & 31, 1998).
- CA-G.R. SP No. 47318 (CA 12th Div.) – CDA sought certiorari to lift RTC TRO; CA issued TRO in favor of CDA and held SP Civil Case No. 25 in abeyance (Apr. 21, 1998).
- CA-G.R. SP No. 47933 (CA 13th Div.) – private respondents filed prohibition to stop June 14 assembly; CA issued TRO (June 10, 1998).
- SP Civil Case No. 28 (RTC Polomolok) – Investa Land Corp. sought nullification of CDA orders and secured TRO (June 11, 1998).
- July 12, 1998 – majority of DARBCI members convened self-initiated assembly, elected new board; private respondents moved for contempt and nullification before CA.
- Court of Appeals Decision and Resolution
- Decision (Sept. 9, 1998) – CA 13th Div. nullified CDA orders and resolutions in CDA-CO No. 97-011, ordered CDA to reinstate private respondents and cease proceedings.
- Resolution (Feb. 9, 1999) – denied CDA’s motion for reconsideration; declared July 12, 1998 election null and void ab initio; directed explanations for contempt.
- Petition for Review on Certiorari to the Supreme Court
- CDA raised assignments of error: lack of jurisdictional basis in CA decision, failure to apply forum-shopping rule, reliance on conjecture.
- CDA asserted quasi-judicial powers under R.A. No. 6939 Sections 3 and 8, DOJ Opinion No. 10 (1995), and OP Case No. 51111.
- Private respondents denied forum-shopping, challenged CDA representation for lack of OSG imprimatur.
Issues:
- Does the CDA possess quasi-judicial authority to adjudicate intra-cooperative disputes, including election controversies?
- Did the Court of Appeals err in nullifying CDA orders and resolutions beyond judicial review?
- Were private respondents guilty of forum-shopping by filing multiple actions seeking similar relief?
- Was the election held on July 12, 1998 properly nullified by the Court of Appeals without due process?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)