G.R. No. 142601 - National Housing Authority vs. Commission on the Settlement of Land Problems

Since 1968, a longstanding boundary dispute existed between the Municipality of San Jose del Monte, Bulacan and the City of Caloocan.
In efforts to resolve the dispute, the Sangguniang Bayan of San Jose del Monte passed Resolution No. 20-02-94 on February 10, 1994, which recognized the official boundary with Caloocan as delineated by the geographic positions and plain grid coordinates specified in CAD-267, particularly from MBM No. 22 to MBM No. 33.

On August 8, 1995, the Sangguniang Bayan of San Jose del Monte passed another resolution affirming the lot lines of Tala Estate, as contained in BM No. 11-24, as the boundary between the municipality and Caloocan City.
This action prompted the Department of Environment and Natural Resources (DENR) Region III to conduct a relocation survey, which produced a Comprehensive Report on September 15, 1995 reflecting:

The comparison between the geographic positions in Cad 267 and the lot lines of Tala Estate.
Discrepancies such as the portrayal of lot lines that traversed through Marilao River and conflicting boundary delineations.

Dissatisfied with the DENR report and the Sangguniang Bayan’s resolutions, the respondent municipality (San Jose del Monte) filed a complaint with the Commission on Settlement of Land Problems (COSLAP) against petitioner National Housing Authority (NHA).
Private respondents, including spouses Angel and Rosario Cruz, Rufino Laan and Rufina Laan Santos, Andres Nepomuceno, spouses Alberto and Herminia Hagos, Leon Guilalas, spouses Oscar and Haydee Badillo, and Leoncio Laan, joined the complaint.
They argued that their properties were within San Jose del Monte, that Presidential Proclamation No. 843 did not apply to their lands, and that the NHA’s Bagong Silang Resettlement Project encroached on their properties.

On June 22, 1998, COSLAP rendered a Resolution finding that the true boundary between San Jose del Monte and Caloocan was as provided by the Sangguniang Bayan resolutions, and it further declared that the NHA project encroached upon the private respondents’ properties.
On January 14, 1999, the NHA participated in a meeting convened by the Bureau of Local Government Supervision to discuss the territorial boundary with both local government units. During the meeting, NHA prominently opposed the COSLAP Resolution, arguing that the commission lacked jurisdiction over a boundary dispute between local government units.
Instead of submitting a required position paper as directed by the Bureau, the respondent municipality moved to execute its COSLAP Resolution, which COSLAP promptly granted by issuing a writ of execution on May 17, 1999.
Petitioner NHA subsequently filed a petition for certiorari with the Court of Appeals alleging that the COSLAP exceeded its jurisdiction. The Court of Appeals dismissed the petition on the grounds of timeliness and on the premise that certiorari is not a substitute for an appeal.
Following the denial of its motion for reconsideration, petitioner NHA elevated the matter to the Supreme Court through a petition for review on certiorari.

Whether the Commission on Settlement of Land Problems (COSLAP) has jurisdiction over the boundary dispute between the Municipality of San Jose del Monte and the City of Caloocan.

Whether the boundary dispute, being between two local government units (LGUs), falls within the exclusive jurisdiction of their respective legislative bodies under Republic Act No. 7160 (Local Government Code) and its implementing rules.
Whether the acts carried out by COSLAP, including the issuance of a Resolution and a writ of execution, are legally valid given its limited mandate.

The effect of a judgment or ruling by a quasi-judicial body that acted without proper jurisdiction, particularly regarding its finality and enforceability.
Whether certiorari is an appropriate remedy to annul decisions rendered without jurisdiction.