Case Summary (G.R. No. 143135)
Factual Background
Damayan ng Purok 14, Inc. claimed possession of an area forming part of a tract segregated from Fort Bonifacio and declared open for disposition by Proclamation No. 172. The association filed a complaint before COSLAP alleging that petitioner had encroached upon a 10,600-square-meter portion of Lot 1, SWO-13-00258 in Barangay Signal Village. After hearing, COSLAP issued a resolution declaring approximately 98,207 square meters of the contested lot as part of Barangay Signal Village and generally not available for government projects. Petitioner moved for reconsideration of the COSLAP resolution, and COSLAP denied that motion by order dated September 4, 1998.
Administrative and Appellate Proceedings
Petitioner instituted a petition for review with the Court of Appeals invoking Rule 43 of the 1997 Rules of Civil Procedure. The Court of Appeals dismissed the petition on March 15, 2000, holding that appeals from COSLAP are by certiorari to the Supreme Court under EO No. 561 and the COSLAP rules, and that appeals taken to the wrong forum must be dismissed pursuant to Supreme Court Circular No. 2-90. The Court of Appeals denied petitioner's motion for reconsideration in a resolution dated May 9, 2000.
Issue Presented
The sole legal question presented was whether the proper appellate forum for a resolution, order, or decision of COSLAP is the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure, or the Supreme Court by certiorari pursuant to Section 3(2) of EO No. 561.
Parties' Contentions
Petitioner maintained that its petition for review to the Court of Appeals was the correct remedy because COSLAP is a quasi-judicial agency whose final orders are appealable to the Court of Appeals under Rule 43, consistent with the judicial hierarchy and the remedial scheme of the Rules of Court. Respondent relied on EO No. 561, specifically Section 3(2), and the procedural rules adopted by COSLAP, which state that COSLAP resolutions are appealable by certiorari only to the Supreme Court, to justify dismissal of the petition to the Court of Appeals.
Ruling of the Supreme Court
The Supreme Court granted the petition and set aside the Court of Appeals' decision dated March 15, 2000, and its resolution dated May 9, 2000. The Court ordered the Court of Appeals to take cognizance of the petition for review filed by petitioner Republic of the Philippines and to resolve it without further delay. The Court made no pronouncement as to costs.
Legal Basis and Reasoning
The Court relied principally on its prior decision in Henry Sy v. Commission on Settlement of Land Problems and Femina Mina, G.R. No. 140903, promulgated September 12, 2001, which addressed the same conflict between EO No. 561 and the appellate provisions of the 1997 Rules of Civil Procedure. The Court observed that COSLAP exercises quasi-judicial functions and that appeals from quasi-judicial agencies are governed by Rule 43, which vests appellate jurisdiction in the Court of Appeals. The Court held that Section 3(2) of EO No. 561, insofar as it declared COSLAP resolutions appealable exclusively to the Supreme Court by certiorari, was erroneous in the light of Section 1, Rule 45 and Section 1, Rule 43 of the 1997 Rules of Civil Procedure. The Court emphasized that bypassing the Court of Appeals would contravene the doctrine of judicial hierarchy. The Court further explained that transferring appellate jurisdiction to the Court of Appeals is a procedural matter and does not create a new substantive right nor impair vested rights, citing the treatment in Fabian as authority for the proposition
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Case Syllabus (G.R. No. 143135)
Parties and Posture
- Republic of the Philippines was the petitioner in the petition for review filed with the Court of Appeals.
- Damayan ng Purok 14, Inc. was the respondent and a registered non-stock, non-profit corporation composed of residents of Purok 14, Zone 3B, Signal Village, Taguig.
- Armed Forces of the Philippines Housing Administration (AFPHA) represented petitioner as an unincorporated office within the AFP organized pursuant to GHO General Order No. 91.
- The petition contested a resolution of the Commission on the Settlement of Land Problems (COSLAP) declaring the area in dispute to be part of Barangay Signal Village.
- The case reached the Supreme Court by way of a petition for review after the Court of Appeals dismissed the matter for being the wrong mode of appeal.
Key Facts
- Damayan ng Purok 14, Inc. alleged that Republic of the Philippines had encroached upon an area comprising 10,600 square meters of Lot 1, SWO-13-00258 in Barangay Signal Village.
- COSLAP, after hearing, declared some 98,207 square meters of the contested lot as part of Barangay Signal Village and generally not available for government projects.
- The land in dispute formed part of a tract segregated from Fort Bonifacio that had been declared open for disposition by Presidential Proclamation No. 172.
- COSLAP denied petitioner's motion for reconsideration in an order dated September 4, 1998.
Administrative Action
- COSLAP acted as a quasi-judicial body in adjudicating the ownership and entitlement over the subject lands.
- COSLAP promulgated a resolution, order, or decision that became final and executory within thirty days and which it initially declared appealable by certiorari only to the Supreme Court under Section 3(2) of E.O. No. 561.
- The COSLAP resolution declared the disputed areas as part of Barangay Signal Village and not available for petitioner’s housing project.
Procedural History
- Petitioner sought reconsideration before COSLAP, which was denied on September 4, 1998.
- Petitioner then filed a petition for review with the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure.