The United Residents of Dominican Hill, Inc. vs. Commission on the Settlement of Land Problems

The Commission on the Settlement of Land Problems (COSLAP) cannot assume jurisdiction over cases already pending in regular courts, its quasi-judicial functions remaining administrative in nature and binding only upon executive agencies, not the judiciary; further, filing multiple petitions across different tribunals to obtain the same injunctive relief based on the same facts constitutes willful forum shopping warranting summary dismissal.

A 10.36-hectare property in Baguio City known as Dominican Hills, formerly mortgaged to the United Coconut Planters Bank (UCPB), was donated to the Republic of the Philippines in 1983 for the Ministry of Human Settlements. Following the Ministry's abolition, the property was transferred to the Presidential Management Staff (PMS). In 1990, PMS, the Home Insurance Guaranty Corporation (HIGC), and petitioner United Residents of Dominican Hill, Inc. (UNITED), a community housing association, executed a Memorandum of Agreement for the sale of the property to UNITED. After full payment, HIGC executed a Deed of Absolute Sale in 1992. Private respondents entered the property in 1993 and constructed houses, prompting petitioner to secure a demolition order from the city mayor.

• The Property and the Sale: Dominican Hills was donated by UCPB to the Republic for human settlement programs. After the Ministry of Human Settlements was abolished, its assets were transferred to the PMS. PMS, HIGC, and UNITED entered into a MOA where PMS would sell the property to HIGC, which would then sell it to UNITED at P75.00 per square meter. HIGC executed a Deed of Absolute Sale on July 1, 1992, after UNITED made its final payment.
• The Intrusion and Demolition Order: In 1993, private respondents entered the portion of Dominican Hills allocated to UNITED and constructed houses. Petitioner secured a demolition order from the city mayor. Private respondents attempted to stop the razing of their houses.
• Multiple Filings by Private Respondents: To forestall the demolition, private respondents filed three separate actions. First, under the name Dominican Hill Baguio Residents Homeless Association (ASSOCIATION), they filed Civil Case No. 3316-R for injunction in RTC Branch 4, securing a TRO but failing to obtain a preliminary injunction. Second, under the Land Reform Beneficiaries Association, Inc. (BENEFICIARIES), they filed Civil Case No. 3382-R for damages, injunction, and annulment of the MOA in RTC Branch 61, which was dismissed. Third, they filed COSLAP Case No. 98-253 for annulment of contracts with a prayer for a TRO, resulting in the contested status quo order.

• COSLAP Jurisdiction: COSLAP lacks the power to hear a petition for annulment of contracts with a prayer for a TRO, and cannot issue a status quo order or conduct hearings thereon.
• Forum Shopping: Private respondents are guilty of forum shopping for filing multiple cases in different tribunals seeking the same injunctive relief.

• COSLAP Jurisdiction: COSLAP has jurisdiction to assume cognizance of the land dispute, given its mandate to resolve land problems that are critical and explosive in nature.
• Forum Shopping: The filing of separate cases does not constitute forum shopping as the parties and causes of action were varied.

• COSLAP Jurisdiction: Whether COSLAP is empowered to hear a petition for annulment of contracts with prayer for a TRO and issue a status quo order, especially when the matter is already pending before the regular courts.
• Forum Shopping: Whether private respondents engaged in forum shopping by filing multiple cases across different tribunals based on the same facts and seeking the same injunctive relief.

• COSLAP Jurisdiction: COSLAP is not justified in assuming jurisdiction over the controversy. While COSLAP exercises quasi-judicial functions, it remains an administrative agency, not a court. Under the principle of ejusdem generis, the phrase "agency having jurisdiction over the same" in Executive Order No. 561 refers to administrative or executive agencies, not the judiciary. COSLAP cannot impose its judgment upon the regular courts where cases are already pending.
• Forum Shopping: Private respondents engaged in willful and deliberate forum shopping. They repetitively availed themselves of several judicial remedies in different tribunals, all founded on the same transactions and essential facts, and raising substantially the same issues to obtain an injunction against the demolition. They also failed to comply with the mandatory certification against forum shopping, submitted false certifications, and failed to notify other courts of pending actions. Varying the designation of parties or the form of the action does not avoid the effects of litis pendentia or res judicata.

• Quasi-Judicial Function of Administrative Agencies — Defined as the actions of public administrative officers required to investigate facts, hold hearings, and draw conclusions as a basis for their official action, exercising discretion of a judicial nature. Administrative agencies are not courts; they are neither part of the judicial system nor deemed judicial tribunals, and cannot impose their judgments upon the judiciary.
• Forum Shopping — Exists when a party repetitively avails of several judicial remedies in different courts, simultaneously or successively, all substantially founded on the same transactions and the same essential facts and circumstances, and all raising substantially the same issues either pending in, or already resolved adversely by some other court. Willful and deliberate forum shopping is punishable by summary dismissal of the actions filed and constitutes direct contempt.
• Certification Against Forum Shopping — Compliance is mandatory and separate from the avoidance of forum shopping itself. Failure to comply with the certification requirement is a cause for dismissal without prejudice, while actual forum shopping is a ground for summary dismissal and constitutes direct contempt. The certification must be executed by the principal party, not by counsel.

• "The COSLAP may not assume jurisdiction over cases which are already pending in the regular courts."
• "Forum shopping exists when a party repetitively avail[s] of several judicial remedies in different courts, simultaneously or successively, all substantially founded on the same transactions and the same essential facts and circumstances, and all raising substantially the same issues either pending in, or already resolved adversely by some other court."
• "Compliance with the certification against forum shopping is separate from, and independent of, the avoidance of forum shopping itself."

• Bañaga v. Commission on the Settlement of Land Problems — Characterized COSLAP's jurisdiction as general in nature, not confined to critical and explosive cases, as it assumed the functions of the abolished PACLAP.
• Viva Productions, Inc. v. Court of Appeals — Cited for the proposition that seeking identical reliefs, such as a preliminary injunction, in different courts manifests an intention to engage in forum shopping and constitutes grave abuse of the judicial process.

• Executive Order No. 561, Section 3(2) — Enumerates COSLAP's powers and functions, including the power to assume jurisdiction over critical and explosive land disputes, and provides that its decisions have the force and effect of a regular administrative resolution, binding upon the parties and the agency having jurisdiction over the same. Interpreted to mean that COSLAP's dispositions are binding only on administrative or executive agencies.
• Supreme Court Administrative Circular No. 04-94 — Requires the submission of a certification against forum shopping in all courts and agencies, and prescribes sanctions for non-compliance or violation. Applied to hold private respondents liable for failing to submit the certification, submitting false certifications, and engaging in actual forum shopping.
• Section 1, Article VIII, 1987 Constitution — Empowers the Supreme Court to determine whether there has been grave abuse of discretion amounting to lack or excess of jurisdiction on the part of any branch or instrumentality of the Government. Cited to emphasize the separation of powers and the judiciary's independence from administrative agencies.

Bellosillo, Mendoza, Quisumbing, and Buena.