United Resident of Dominican Hills vs. Commission on the Settlement of Land Problems

THE UNITED RESIDENTS OF DOMINICAN HILL, INC., vs. COMMISSION ON THE SETTLEMENT OF LAND PROBLEMS

G.R. No. 135945                                                                                              March 7, 2001

TOPIC: AN EXECUTIVE AGENCY IS NOT A COURT.

FACTS: Dominican Hills, formerly registered as Diplomat Hills in Baguio City, was mortgaged to the United Coconut Planters Bank (UCPB).  It was eventually foreclosed and acquired later on by the said bank as the highest bidder.  On 11 April 1983, through its President Eduardo Cojuangco Jr., the subject property was donated to the Republic of the Philippines.  The deed of donation stipulated that Dominican Hills would be utilized for the "priority programs, projects, activities in human settlements and economic development and governmental purposes" of the Ministry of Human Settlements.

On December 12, 1986, then President Corazon Aquino issued EO 85 abolishing the Ministry of Human Settlements. All agencies under the its supervision as well as all its assets, programs and projects, were transferred to the Presidential Management Staff (PMS).

On 18 October 1988, United (Dominican Hills) submitted its application before the PMS to acquire a portion of the Dominican Hills property.  In a MOA, PMS and United agreed that the latter may purchase a portion of the said property from HOME INSURANCE GUARANTY CORPORATIO, acting as originator,  on a selling price of P75.00 per square meter.

Thus, on June 12, 1991, HIGC sold 2.48 hectares of the property to UNITED. The deed of conditional sale provided that ten (10) per cent of the purchase price would be paid upon signing, with the balance to be amortized within one year from its date of execution. After UNITED made its final payment on January 31, 1992, HIGC executed a Deed of Absolute Sale dated July 1, 1992.

Petitioner alleges that sometime in 1993, private respondents entered the Dominican Hills property allocated to UNITED and constructed houses thereon. Petitioner was able to secure a demolition order from the city mayor.  Unable to stop the razing of their houses, private respondents, under the name DOMINICAN HILL BAGUIO RESIDENTS HOMELESS ASSOCIATION (ASSOCIATION, for brevity) filed an action for injunction before RTC Baguio City.  Private respondents were able to obtain a temporary restraining order but their prayer for a writ of preliminary injunction was later denied. 

The ASSOCIATION filed a separate civil case for damages, injunction and annulment of the said MOA.  It was later on dismissed upon motion of United. The said Order of dismissal is currently on appeal with the Court of Appeals.

The demolition order was subsequently implemented by the Office of the City Mayor and the City Engineer's Office of Baguio City. However, petitioner avers that private respondents returned and reconstructed the demolished structures.

To forestall the re-implementation of the demolition order, private respondents filed a petition for annulment of contracts with prayer for a temporary restraining order before the Commission on the Settlement of Land Problems (COSLAP) against petitioner, HIGC, PMS, the City Engineer's Office, the City Mayor, as well as the Register of Deeds of Baguio City. On the very same day, public respondent COSLAP issued the contested order requiring the parties to maintain the status quo.  Without filing a motion for reconsideration from the aforesaid status quo order, petitioner filed the instant petition questioning the jurisdiction of the COSLAP.

ISSUE: W/O COSLAP is empowered to hear and try a petition for annulment of contracts with prayer for a TRO and to issue a status quo order and conduct a hearing thereof?

RULING:  COSLAP is not justified in assuming jurisdiction over the controversy. It discharges quasi-judicial functions: 

"Quasi-judicial function" is a term which applies to the actions, discretion, etc. of public administrative officers or bodies, who are required to investigate facts, or ascertain the existence of facts, hold hearings, and draw conclusions from them, as a basis for their official action and to exercise discretion of a judicial nature."

However, it does not depart from its basic nature as an administrative agency, albeit one that exercises quasi-judicial functions. Still, administrative agencies are not considered courts; they are neither part of the judicial system nor are they deemed judicial tribunals. The doctrine of separation of powers observed in our system of government reposes the three (3) great powers into its three (3) branches — the legislative, the executive, and the judiciary — each department being co-equal and coordinate, and supreme in its own sphere. Accordingly, the executive department may not, by its own fiat, impose the judgment of one of its own agencies, upon the judiciary. Indeed, under the expanded jurisdiction of the Supreme Court, it is empowered "to determine whether or not there has been grave abuse of discretion amounting to lack of or excess of jurisdiction on the part of any branch or instrumentality of the Government."