Cooperative Development Authority vs. Dolefil Agrarian Reform Beneficiaries Cooperative, Inc.
The petition challenging the Court of Appeals' nullification of CDA orders was denied. The CDA was declared devoid of quasi-judicial authority to adjudicate intra-cooperative disputes, its statutory mandate under R.A. 6939 being limited to administrative, mediation, and conciliation functions. Legislative history reveals a deliberate intent to withhold such powers to preserve cooperative autonomy and prevent government interference. Furthermore, the appellate court's nullification of the July 12, 1998 election was set aside for violating the intervenors' right to due process, they not having been given an opportunity to be heard on the matter.
Primary Holding
The Cooperative Development Authority is devoid of quasi-judicial authority to adjudicate intra-cooperative disputes, its statutory mandate under R.A. 6939 being limited to administrative, mediation, and conciliation functions.
Background
In late 1997, certain members of the Dolefil Agrarian Reform Beneficiaries Cooperative, Inc. (DARBCI) filed complaints with the CDA alleging mismanagement and misappropriation of funds by incumbent officers. Acting on these complaints, the CDA issued orders directing the officers to answer, freezing the cooperative's funds, creating a management committee, and placing the officers under preventive suspension.
History
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DARBCI members filed complaints with the CDA (CDA-CO Case No. 97-011); CDA issued orders freezing funds, creating a management committee, and suspending incumbent officers.
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Private respondents filed Petition for Certiorari with RTC Polomolok, South Cotabato (SP Civil Case No. 25) questioning CDA jurisdiction; RTC issued TRO restoring status quo.
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CDA filed Certiorari with CA 12th Division (CA-G.R. SP No. 47318) questioning the RTC TRO; CA issued TRO enjoining the RTC proceedings.
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CDA issued resolution directing a special general assembly and election; private respondents filed Petition for Prohibition with CA 13th Division (CA-G.R. SP No. 47933); CA issued TRO against the election.
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CA 13th Division granted the petition in CA-G.R. SP No. 47933, nullifying the CDA orders for lack of jurisdiction; CA subsequently denied the CDA's motion for reconsideration and nullified the July 12, 1998 election.
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CDA filed Petition for Review on Certiorari with the Supreme Court.
Facts
- The CDA Complaints: In late 1997, DARBCI members filed complaints with the CDA (CDA-CO Case No. 97-011) alleging mismanagement by incumbent officers (private respondents). CDA Executive Director Candelario L. Verzosa, Jr. ordered respondents to answer. Subsequently, CDA Administrator Alberto P. Zingapan issued a "freeze order" on DARBCI funds and created a management committee.
- Judicial Challenges: On December 18, 1997, private respondents filed a Petition for Certiorari with the RTC of Polomolok, South Cotabato (SP Civil Case No. 25), questioning the CDA's jurisdiction. The RTC issued a TRO restoring the status quo. The CDA then filed a certiorari petition with the CA 12th Division (CA-G.R. SP No. 47318), which issued a TRO enjoining the RTC proceedings.
- Escalation and TROs: On February 24, 1998, the CDA Chairman placed respondents under preventive suspension. On May 26, 1998, CDA Administrator Arcadio S. Lozada directed a special general assembly and election for June 14, 1998. Private respondents filed a Petition for Prohibition with the CA 13th Division (CA-G.R. SP No. 47933), which issued a TRO against the election. Investa Land Corporation also filed a petition with the RTC (SP Civil Case No. 28), resulting in another TRO.
- The July 12 Election: Despite the TROs, the majority of DARBCI members convened a general assembly on July 12, 1998, and elected new officers, ousting private respondents. Private respondents filed Twin Motions for Contempt and to Nullify with the CA.
- Appellate Court Rulings: The CA 13th Division granted the prohibition petition, nullifying the CDA orders for lack of jurisdiction. In its Resolution on the motion for reconsideration, the CA nullified the July 12 election nunc pro tunc for defying the TRO.
Arguments of the Petitioners
- Quasi-Judicial Authority: Petitioner maintained that it is vested with quasi-judicial authority to adjudicate cooperative disputes pursuant to its powers under Section 3 of R.A. No. 6939, citing DOJ Opinion No. 10, Series of 1995 and an Office of the President ruling.
- Implied Powers: Petitioner argued that its authority to conduct hearings and cite for contempt necessarily implies quasi-judicial authority.
- CANORECO Precedent: Petitioner averred that CANORECO v. Torres affirmed the CDA's adjudicatory powers.
- Forum-Shopping: Petitioner claimed private respondents were guilty of forum-shopping by filing cases in three different fora seeking the same relief.
Arguments of the Respondents
- Lack of Authority to File: Respondents contended that the petition should be dismissed for lack of OSG imprimatur and board approval.
- No Quasi-Judicial Power: Respondents countered that the CDA's powers are merely regulatory, supervisory, and limited to mediation and conciliation.
- No Forum-Shopping: Respondents argued that the RTC case (certiorari) and CA case (prohibition) involved different causes of action and times. Investa is a separate juridical entity with different counsel.
Issues
- Quasi-Judicial Jurisdiction: Whether the CDA possesses quasi-judicial authority to adjudicate intra-cooperative disputes.
- Forum-Shopping: Whether private respondents are guilty of forum-shopping.
- Due Process: Whether the appellate court properly nullified the July 12, 1998 election without giving the intervenors an opportunity to be heard.
Ruling
- Quasi-Judicial Jurisdiction: Quasi-judicial authority was found to be lacking. R.A. 6939 grants the CDA purely administrative functions. Section 8 limits the CDA to mediation and conciliation, requiring a certificate of non-resolution before court action. Legislative history reveals a deliberate intent to withhold quasi-judicial powers to preserve cooperative autonomy and prevent government interference. The reliance on CANORECO was deemed misplaced, as that case actually noted the CDA's lack of jurisdiction over intra-cooperative disputes.
- Forum-Shopping: Forum-shopping was not established. There was no identity of rights asserted between the RTC certiorari case and the CA prohibition case, as they assailed different acts. Investa is a separate entity with different interests and counsel.
- Due Process: The nullification of the July 12 election violated the intervenors' due process rights. The appellate court acted precipitately without requiring the intervenors to comment on the twin motions, especially since the validity of the July 12 election was not an issue in the original petition.
Doctrines
- Principle of Non-Interference in Cooperatives — The State maintains a policy of non-interference in the management and operation of cooperatives, as mandated by R.A. 6939. This necessitates withholding quasi-judicial adjudicatory powers from the CDA to prevent the "kiss of death" from stifling government control.
- Litis Pendentia / Forum-Shopping — Forum-shopping requires identity of parties, identity of rights asserted/facts, and identity such that judgment in one amounts to res judicata in the other. The absence of one requisite negates forum-shopping. Identity of counsel does not equate to identity of parties.
- Due Process in Court Proceedings — Due process requires a court or tribunal with judicial power, lawfully acquired jurisdiction, opportunity to be heard, and judgment upon lawful hearing. Nullifying an election without requiring the affected parties to comment violates this right.
Key Excerpts
- "The decision to withhold quasi-judicial powers from the CDA is in accordance with the policy of the government granting autonomy to cooperatives... While the government wished to help, it invariably wanted to control... The strong embrace of government ends with a kiss of death for cooperatives."
- "Being an administrative agency, the CDA has only such powers as are expressly granted to it by law and those which are necessarily implied in the exercise thereof."
Precedents Cited
- CANORECO v. Hon. Ruben D. Torres — Distinguished. The central issue was the Office of the President's authority to reverse the CDA, and the Court therein actually noted the CDA's lack of jurisdiction to adjudicate intra-cooperative disputes.
- Gonzales v. Chavez — Followed regarding the mandatory character of the OSG's duty to represent the government in legal proceedings.
Provisions
- Section 3, Republic Act No. 6939 — Enumerates the powers, functions, and responsibilities of the CDA; construed as granting purely administrative, not quasi-judicial, functions.
- Section 8, Republic Act No. 6939 — Limits the CDA's dispute resolution role to mediation and conciliation; requires a certificate of non-resolution before filing appropriate action in court.
- Article 121, Republic Act No. 6938 (Cooperative Code) — Settlement of disputes shall be amicably settled, and if conciliation fails, settled in a court of competent jurisdiction.
- Section 35(1) and (8), Administrative Code of 1987 — Defines the OSG's power to represent the government and its agencies, and to deputize legal officers.
Notable Concurring Opinions
Bellosillo, Mendoza, Quisumbing, and Corona, JJ.