Case Digest (G.R. No. 143135)
Facts:
Petitioner Republic of the Philippines, represented by the Armed Forces of the Philippines Housing Administration (AFPHA), sought to develop portions of land segregated from Fort Bonifacio under Proclamation No. 172. Respondent Damayan ng Purok 14, Inc., a non-stock, non-profit whose members occupy Purok 14, Zone 3B, Signal Village, filed a complaint with COSLAP alleging encroachment on Lot 1, SWO-13-00258.
After hearing, COSLAP resolved that about 98,207 square meters of the lot formed part of Barangay Signal Village and denied petitioner's motion for reconsideration dated September 4, 1998; petitioner filed a petition for review under Rule 43 of the 1997 Rules of Civil Procedure in the Court of Appeals, which dismissed it on March 15, 2000, as the wrong mode of appeal and denied reconsideration.
Issues:
- To which court should the decision of the COSLAP be appealed?
Ruling:
The Court granted the petition and held that appeals from COSLAP must be taken to the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure. The Court set aside the Court of Appeals' dismissal and its denial of reconsideration and ordered the Court of Appeals to take cognizance of the petition for review without further delay; no pronouncement as to costs.
Ratio:
The Court relied on Henry Sy v. Commission on Settlement of Land Problems and Femina Mina, G.R. No. 140903 (Sept. 12, 2001), which characterized COSLAP as a quasi-judicial agency and held that appeals from its orders, resolutions, or decisions lie to the Court of Appeals under Rule 43, noting that Section 3(2) of EO No. 561 conflicted with Rule 45 and Rule 43, and that transferring appellate jurisdiction to the Court of Appeals is procedural and permissible.
Doctrine:
- Appeals from quasi-judicial agencies such as COSLAP shall be taken to the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure.
- Section 3(2) of EO No. 561 is erroneous insofar as it declares appeals from COSLAP to be exclusively to the Supreme Court in conflict with Rule 45 and Rule 43.
- The transfer of appellate jurisdiction to the Court of Appeals is procedural and applies to pending cases.