National Housing Authority vs. Commission on the Settlement of Land Problems

A boundary dispute between a component city or municipality and a highly urbanized city falls exclusively within the jurisdiction of their respective sanggunians under Sections 118 and 119 of the Local Government Code, not the Commission on the Settlement of Land Problems (COSLAP). A judgment rendered by a quasi‑judicial body without jurisdiction is void, never acquires finality, and any writ of execution based on it is a nullity correctable by certiorari at any time.

Since 1968, the Municipality of San Jose del Monte, Bulacan, and the City of Caloocan disputed their common territorial boundary. The Sangguniang Bayan of San Jose del Monte passed two resolutions — on February 10, 1994 and August 8, 1995 — recognizing certain geographic coordinates and Tala Estate lot lines as the boundary. The Department of Environment and Natural Resources (DENR) conducted a relocation survey and reported that the Sangguniang Bayan’s delineation conflicted with SWO‑41615 of the Tala Estate, which used the Marilao River as the natural boundary. The Tala Estate is a 598‑hectare government‑owned property allocated for housing and resettlement and administered by the National Housing Authority (NHA) under Presidential Proclamation No. 843 (1971). In the ensuing proceedings, private respondents — landowners who claimed their properties lay within San Jose del Monte and were encroached upon by NHA’s Bagong Silang Resettlement Project — joined the municipality as complainants.

• The Boundary Dispute and Municipal Resolutions: Since 1968, the Municipality of San Jose del Monte, Bulacan, and the City of Caloocan contested their territorial boundary. On February 10, 1994, the Sangguniang Bayan of San Jose del Monte passed Resolution No. 20‑02‑94 recognizing the geographic positions of Municipal Boundary Monuments (MBM) 22 to 33 of Cad‑267, Caloocan Cadastre, as the official boundary line. On August 8, 1995, it passed Resolution No. 06‑08‑95 (Kapasiyahan Blg. 06‑08‑95), which recognized the Tala Estate lot lines based on BM Nos. 11‑24 as the boundary, thereby rejecting the Marilao River as the natural boundary.

• The DENR Comprehensive Report: At the request of the DENR, a relocation survey was conducted. The September 15, 1995 Comprehensive Report found that MBM Nos. 23‑30, 32, and 33 aligned closely with BM Nos. 12‑16, 18‑20, 22, and 23 of the Tala Estate. If the Tala Estate lot lines under SWO‑41615 were used as the boundary, the Marilao River would be the natural boundary; if the Sangguniang Bayan’s resolutions were followed, northern portions of Parcels 1, 2, and 3 of SWO‑41615, as well as portions of Bankers Village and Pangarap Village, would fall within San Jose del Monte. Both interpretations affected the Tala Estate — a 598‑hectare property reserved for housing and resettlement, administered by the NHA under Presidential Proclamation No. 843.

• COSLAP Complaint: Dissatisfied with the DENR report, respondent municipality filed a complaint with COSLAP against NHA, joined as co‑complainants by the private respondents — landowners who alleged that their properties were in San Jose del Monte, that Presidential Proclamation No. 843 did not cover their land, and that the NHA’s Bagong Silang Resettlement Project encroached on their holdings. They prayed for damages. The City of Caloocan was not impleaded.

• COSLAP Resolution and Writ of Execution: On June 22, 1998, COSLAP ruled that the correct boundary was the one specified in the twin Sangguniang Bayan resolutions and held that all other issues (including respondents’ claims) were mere incidents of that ruling, effectively finding that NHA’s project encroached on respondents’ properties. On May 17, 1999, COSLAP granted the municipality’s motion for execution and issued a writ of execution.

• Attempt at Amicable Settlement: On January 14, 1999, the Bureau of Local Government Supervision of the Department of the Interior and Local Government invited NHA and the local officials of San Jose del Monte and Caloocan City to a meeting on January 26, 1999 to discuss the boundary. NHA voiced strong opposition to the COSLAP Resolution, asserting that COSLAP lacked jurisdiction. The Bureau directed the parties to submit position papers within 30 days; respondent municipality opted instead to pursue execution before COSLAP.

• Proceedings before the Court of Appeals: NHA filed a petition for certiorari with the Court of Appeals, arguing that COSLAP acted without jurisdiction. The appellate court dismissed the petition because it was filed out of time and because certiorari could not substitute for a lost appeal.

• Lack of Jurisdiction: Petitioner NHA argued that COSLAP had no jurisdiction over the boundary dispute between the Municipality of San Jose del Monte and Caloocan City. It maintained that the Local Government Code vests exclusive jurisdiction over such disputes in the respective sanggunians of the contending local government units, and that COSLAP’s enabling law, Executive Order No. 561, does not confer authority to adjudicate inter‑LGU boundary conflicts.

• Void Judgment and Proper Remedy: NHA contended that because COSLAP’s resolution was issued without jurisdiction, it was void ab initio and could never become final; hence, certiorari was the appropriate remedy regardless of the lapse of time, and the Court of Appeals erred in dismissing the petition on procedural grounds.

• Boundary and Property Rights: Respondent Municipality of San Jose del Monte and the private respondents argued that the Sangguniang Bayan’s delineations constituted the true boundary, that the NHA‑administered Tala Estate encroached upon properties lying within the municipality, and that Presidential Proclamation No. 843 did not cover their land. They sought damages for the encroachment.

• COSLAP’s Authority: By filing the complaint with COSLAP, respondents implicitly took the position that the dispute fell within COSLAP’s mandate to settle critical and explosive land problems, although the decision does not detail any formal argument that COSLAP possessed jurisdiction under Section 3(2)(e) of Executive Order No. 561.

• Jurisdiction of COSLAP: Whether the Commission on the Settlement of Land Problems has jurisdiction over a territorial boundary dispute between a municipality and a highly urbanized city.

• Jurisdiction of COSLAP: COSLAP had no jurisdiction over the boundary dispute. Executive Order No. 561 limits COSLAP’s adjudicatory authority to the specific categories enumerated in Section 3(2)(a)‑(e) — disputes between small settlers and pasture‑lease holders, timber concessionaires, government reservation grantees, public land claimants, and petitions for classification and release of public lands — or it may refer a matter to the appropriate agency. There is no provision granting COSLAP power over boundary disputes between local government units. Under Sections 118 and 119 of the Local Government Code (Republic Act No. 7160), boundary disputes involving a component city or municipality and a highly urbanized city must be jointly referred to the respective sanggunians of the parties; if amicable settlement fails, the sanggunian concerned decides the dispute, and any appeal lies to the proper Regional Trial Court. Because COSLAP acted without jurisdiction, its Resolution and writ of execution were void. A void judgment never attains finality, and certiorari may be availed of at any time to declare its nullity. Consequently, the Court of Appeals should have dismissed NHA’s petition not on grounds of tardiness or incorrect remedy but solely because COSLAP lacked jurisdiction.

• Void Judgment for Want of Jurisdiction — A judgment rendered by a tribunal without jurisdiction over the subject matter is a complete nullity. It cannot be the source of any right or create any obligation. All acts performed pursuant to it and all claims emanating from it have no legal effect. It never becomes final, and any action to declare its nullity does not prescribe; certiorari may be filed at any time to set aside such void judgment, and the defense of timeliness does not lie. The situation is the same as if no judgment had been rendered, leaving the parties in the positions they occupied before the proceedings.

• Exclusive Jurisdiction over LGU Boundary Disputes — Under the Local Government Code (R.A. No. 7160), boundary disputes between a component city or municipality and a highly urbanized city must be settled exclusively by the respective sanggunians concerned. Section 118(d) directs joint referral to the sanggunians; if amicable settlement is not reached within 60 days, the sanggunian that issued the certification of failure decides the dispute within 60 days (Section 118(e)). The decision may be appealed to the Regional Trial Court having jurisdiction over the area in dispute (Section 119). This statutory mechanism is exclusive and precludes the assumption of jurisdiction by COSLAP.

• “[A] judgment issued by a quasi‑judicial body without jurisdiction is void. It can never become final and executory, hence, an appeal is out of the question.” — Establishes the threshold principle that voids the COSLAP resolution and justifies certiorari as the proper remedy.

• “We have consistently ruled that a judgment for want of jurisdiction is no judgment at all. It cannot be the source of any right or the creator of any obligation. All acts performed pursuant to it and all claims emanating from it have no legal effect. Hence, it can never become final and any writ of execution based on it is void.” — The core statement on the effect of a void judgment, extensively cited in subsequent cases.

• “Such nullity is correctable only by certiorari. And certiorari cannot be dismissed for timeliness inasmuch as a void judgment never acquires finality and any action to declare its nullity does not prescribe.” — Resolves the procedural issue that led the Court of Appeals to dismiss the petition.

• Longino v. General, et al., G.R. No. 147956, February 16, 2005, 451 SCRA 423 — Cited for the principle that administrative agencies like COSLAP possess only limited jurisdiction specifically granted by enabling statutes, and for the rule that a judgment without jurisdiction is void.

• Leonor v. Court of Appeals, G.R. No. 112597, April 2, 1996, 256 SCRA 69 — Relied upon for the doctrine that a void judgment cannot become final, is not a source of rights, and any writ based on it is void.

• Cochingyan, Jr. v. Cloribel, et al., Nos. L‑27070‑71, April 22, 1977, 76 SCRA 361 — Cited for the rule that nullity for want of jurisdiction is correctable only by certiorari.

• Heirs of Mayor Nemencio Galvez v. Court of Appeals, G.R. No. 119193, March 29, 1996, 255 SCRA 672 — Used to support that an action to declare the nullity of a void judgment does not prescribe and that certiorari cannot be dismissed on timeliness grounds.

• MWSS v. Sison, No. L‑40309, August 31, 1983, 124 SCRA 394 — Cited for the proposition that a void judgment leaves the parties in the position they were in before the trial.

• Section 3, Executive Order No. 561 (1979) — Enumerates the powers and functions of COSLAP, including the authority to assume jurisdiction only over specific categories of land disputes (e.g., between small settlers and pasture‑lease holders, timber concessionaires, government reservation grantees, public land claimants, and similar critical land problems). The provision contains no grant of jurisdiction over boundary disputes between local government units. The Court applied it to demonstrate that COSLAP exceeded its limited authority.

• Sections 118 and 119, Republic Act No. 7160 (Local Government Code of 1991) — Establish the exclusive mechanism for settling boundary disputes. Section 118(d) mandates joint referral to the sanggunians of the parties for disputes between a component city/municipality and a highly urbanized city. Section 118(e) provides for sanggunian adjudication if amicable settlement fails. Section 119 provides for appeal to the Regional Trial Court. The Court enforced these provisions to hold that COSLAP should have referred the complaint to the sanggunians rather than assuming jurisdiction.

• Rule III, Articles 15 and 16(d), Implementing Rules and Regulations of the Local Government Code — Reiterate the policy of amicable settlement and the jurisdictional responsibility for boundary disputes, specifying joint referral to the respective sanggunians for disputes involving a component city or municipality and a highly urbanized city. The Court invoked these implementing rules to confirm the exclusive and mandatory nature of the procedure.

Puno, J. (Chairperson), Corona, Azcuna, and Garcia, JJ., concurred.