GR 137489; (May, 2002) (Digest)
G.R. No. 137489 ; May 29, 2002
COOPERATIVE DEVELOPMENT AUTHORITY, petitioner, vs. DOLEFIL AGRARIAN REFORM BENEFICIARIES COOPERATIVE, INC., ESMERALDO A. DUBLIN, ALICIA SAVAREZ, EDNA URETA, ET AL., respondents.
FACTS
The Cooperative Development Authority (CDA) received complaints from members of Dolefil Agrarian Reform Beneficiaries Cooperative, Inc. (DARBCI) alleging mismanagement and misappropriation of funds by its incumbent officers. The CDA, acting on these complaints in CDA-CO Case No. 97-011, issued orders freezing DARBCI’s funds, creating a management committee, and later placing the officers under preventive suspension. The CDA also issued a resolution directing a special general assembly and election for new officers.
DARBCI officers filed a Petition for Certiorari with the Regional Trial Court (RTC) of Polomolok, primarily questioning the CDA’s jurisdiction to issue the “freeze order” and create a management committee. The RTC issued a temporary restraining order. The CDA challenged this order before the Court of Appeals. Subsequently, the private respondents also filed a Petition for Prohibition with the Court of Appeals (CA-G.R. SP No. 47933) to restrain the CDA from proceeding with the scheduled election. The CA issued a restraining order.
ISSUE
Whether the Cooperative Development Authority (CDA) is vested with quasi-judicial authority to adjudicate intra-cooperative disputes, including the power to issue ancillary orders such as freezing funds and creating management committees.
RULING
No. The Supreme Court affirmed the Court of Appeals’ decision, ruling that the CDA lacks quasi-judicial authority to adjudicate intra-cooperative disputes. The legal logic is anchored on statutory construction. Republic Act No. 6939 , which created the CDA, and its successor, Republic Act No. 6938 (the Cooperative Code), do not expressly grant the CDA adjudicatory powers. The CDA’s functions under the law are primarily administrative, promotional, developmental, regulatory, and supervisory in character. Quasi-judicial power, which entails the authority to hear and determine controversies and render binding judgments, cannot be implied; it must be expressly conferred by law. Since the law did not grant such express power to the CDA, its assumption of jurisdiction over the intra-cooperative dispute, including its issuance of the “freeze order” and the creation of a management committee, was an act in excess of its jurisdiction and therefore null and void. The proper remedy for the complaining members was to seek redress before the regular courts or through the arbitration mechanisms provided in the cooperative’s bylaws.