Case Summary (G.R. No. 92649)
Factual Background of the Case
In 1966, David Quema mortgaged two parcels of land in Lucaga for P6,000. After redeeming the land in 1988, Quema claimed ownership despite Rosa Badua's assertion that the land was sold to her by the deceased owner, Dra. Erotida Valera. Rosa did not have a deed of sale readily available, claiming it was with a local official. Following failed attempts to resolve the matter at the barangay level, Quema brought the dispute to a tribal court, which in February 1989 awarded him ownership of the land and imposed penalties on the Baduas.
Notice and Coercion from Respondents
The situation escalated when the Baduas failed to vacate the land, leading to a warning issued by Ka Blantie of the CPLA, threatening physical repercussions if they did not comply with the tribal court's decision. Fear of violence compelled Leonor Badua to go into hiding after an incident involving the arrest of Rosa by the CPLA, which heightened the urgency for the Baduas to seek legal redress.
Legal Claims of the Petitioners
The Baduas filed a petition before the Supreme Court seeking injunctive relief and declaring the authority of the Cordillera Bodong Administration as invalid. They claimed violations of due process, arguing that they were not properly heard, and contended that the Administration lacked jurisdiction over them since neither was a member of the Maeng Tribe, the indigenous group involved in the tribal court's ruling.
Response from the Respondents
The respondents, represented by Atty. Demetrio V. Pre, asserted the legitimacy of the tribal court's decisions, highlighting the custom of the Maeng Tribe to resolve disputes through tribal courts. They argued that these courts operate independently of the formal Philippine judicial system and are widely accepted by community members.
Jurisdictional Issues Raised by the Court
Upon reviewing the case, the Supreme Court noted that the Cordillera Autonomous Region, which could have legitimized the CBA and CPLA, had been rejected in a plebiscite held in January 1990. As such, the court determined that the Maeng Tribal Court did not have the requisite legal standing as an indigenous or special court and, in essence, lacked judicial power under the 1987 Philippine Constitution.
Ruling and Conclusion
The Supreme Court found the petition to be meritorious, ruling that the decision made by the Maeng Tribal Court lacked jurisdiction and was therefore null and void. It mandate
...continue readingCase Syllabus (G.R. No. 92649)
Case Citation
- 271 Phil. 932 EN BANC
- G.R. No. 92649
- Date of Decision: February 14, 1991
Parties Involved
- Petitioners: Spouses Leonor and Rosa Badua
- Respondents: Cordillera Bodong Administration, Cordillera People’s Liberation Army, Manuel Tao-il, Amogao-en Kissip, Dalalo Illiques, Juanito Gayyed, Pedro Cabanto, Vicente Dayem, and David Quema
Legal Issue
- The legal issue at hand concerns whether the tribal court of the Cordillera Bodong Administration can render a valid and executory decision in a land dispute.
Factual Background
- The petitioners, Leonor and Rosa Badua, claim ownership of farmland in Lucaga, Lumaba, Villaviciosa, Abra.
- In July 1989, the petitioners were forcibly ejected from their land based on a "decision" from the Cordillera Bodong Administration in Case No. 0, involving David Quema.
- Historical Context:
- David Quema allegedly owned two parcels of land, evidenced by Tax Declarations Nos. 4997 and 4998, which he mortgaged for P6,000 to Dra. Erotida Valera in 1966.
- Quema redeemed the land on August 14, 1988, paying P10,000 to the mortgagee's heir, Jessie Macaraeg.
- Rosa Badua claimed that Dra. Valera sold the land to her, but she could not produce the deed of sale as it was supposedly with Vice-Governor Benesa.
- Initial Dispute Resolution Attempts:
- Quema's attempt to resolve the dispute at the Barangay Council failed.
- Following a suggestion from Judge Cacho, Quema approached the tribal court of the Maeng Tribe instead.
Tribal Court Proceedings
- The Maeng Tribal Court conducted a trial on February 19, 1989, and rendered a decision that:
- Awarded the land to David Quema.
- Ordered the Baduas