G.R. No. 141523; June 8, 2005
DAVAO NEW TOWN DEVELOPMENT CORPORATION, Petitioner, vs. COMMISSION ON THE SETTLEMENT OF LAND PROBLEMS (COSLAP), Public Respondent, and various Private Respondents.

FACTS

The case involves a 131-hectare property in Davao City, originally owned by Roman Cuison, Jr. and mortgaged to Philippine Banking Corporation (PBC). After foreclosure, PBC acquired the land. In 1989, the government compulsorily acquired the property under the Comprehensive Agrarian Reform Program (CARP) and issued Certificates of Land Ownership Award (CLOAs) to private respondents, farmer-beneficiaries. PBC challenged this acquisition before the Department of Agrarian Reform Adjudication Board (DARAB), arguing the land was classified as “urban/urbanizing” since 1982 and thus exempt from CARP. The Provincial Adjudicator and later the DARAB upheld PBC’s claim, declaring the land outside CARP coverage and ordering the cancellation of the CLOAs. PBC’s title was reinstated, and petitioner Davao New Town Development Corporation subsequently purchased the property.
While the DARAB case was on appeal, private respondents filed a complaint with the Commission on the Settlement of Land Problems (COSLAP), alleging forcible eviction by the petitioner. COSLAP assumed jurisdiction and issued a resolution ordering the parties to maintain the status quo and enjoining any activity that would disturb the farmer-beneficiaries’ possession. Petitioner filed this special civil action for certiorari and prohibition, seeking to annul the COSLAP Resolution for lack of jurisdiction.

ISSUE

Whether the Commission on the Settlement of Land Problems (COSLAP) has jurisdiction over the land dispute involving the subject property.

RULING

No, COSLAP has no jurisdiction. The Supreme Court granted the petition and nullified the COSLAP Resolution. The legal logic is anchored on the doctrine of primary jurisdiction and the specific mandate of COSLAP under Presidential Decree No. 832. The dispute is fundamentally agrarian, involving the correctness of the compulsory acquisition of land under CARP, the validity of the CLOAs issued, and the subsequent cancellation of titles. These matters fall squarely within the exclusive original jurisdiction of the Department of Agrarian Reform (DAR) and its adjudicatory arm, the DARAB, as provided by Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
COSLAP’s jurisdiction is limited to assisting parties and referring land disputes to the appropriate government agency for settlement. It is not a quasi-judicial body with adjudicatory powers over contentious cases like the present one, which involves a clear controversy over land ownership and tenurial rights already pending before and decided by the DARAB. The Court emphasized that COSLAP cannot arrogate unto itself jurisdiction over cases explicitly vested by law in other specialized agencies. Since the DARAB had already rendered a decision on the merits, COSLAP’s assumption of jurisdiction constituted a grave abuse of discretion for being without legal authority.