G.R. No. 66386; January 30, 1990
GUILLERMO BANAGA and Heirs of JOSE C. TOLEDO, petitioners, vs. COMMISSION ON THE SETTLEMENT OF LAND PROBLEMS and GREGORIO DAPROZA, SR., respondents.

FACTS

The dispute originated from a 1961 verbal agreement between Gregorio Daproza, Sr. and Jose Toledo. Daproza, unable to afford the full purchase price for a 30-hectare lot, arranged for Toledo to buy it with the understanding that Toledo would later resell one-half to Daproza upon reimbursement. Toledo purchased the land in 1962. Daproza made an initial payment in 1963. However, in 1965, Toledo, without Daproza’s knowledge, conveyed a major portion of the land (Lot 1) to his son-in-law, Guillermo Banaga, who filed a free patent application for it. Daproza, upon learning of this, filed a protest with the Bureau of Lands and his own free patent application for a specific half-share. The Bureau of Lands failed to resolve the conflicting claims despite several orders for investigation.
Given the protracted inaction, Daproza sought the intervention of the Presidential Action Committee on Land Problems (PACLAP) in 1972. The PACLAP initially deferred to the Bureau of Lands but, after no progress was made, its Provincial Committee eventually assumed jurisdiction, conducted hearings, and in 1978 ruled in favor of Daproza, recognizing the partially executed verbal agreement and ordering the segregation of a portion for him. This resolution was affirmed by the Commission on the Settlement of Land Problems (COSLAP) in 1983. Petitioners Banaga and Toledo’s heirs then filed this certiorari petition, challenging COSLAP’s jurisdiction.

ISSUE

Whether the Commission on the Settlement of Land Problems (COSLAP) validly exercised jurisdiction over the land dispute between the parties.

RULING

The Supreme Court dismissed the petition and affirmed the COSLAP decision. The Court held that COSLAP validly exercised jurisdiction. Petitioners argued that jurisdiction belonged exclusively to the Bureau of Lands as the dispute involved public land applications. The Court rejected this, explaining that COSLAP’s jurisdiction under its charter (Executive Order No. 561) is broad and includes disputes involving public lands where other government agencies fail to act. The factual antecedents showed the Bureau of Lands’ failure to resolve the case for years despite directives, justifying COSLAP’s assumption of jurisdiction to prevent further delay.
Furthermore, the Court ruled that petitioners were estopped from challenging COSLAP’s jurisdiction. They actively participated in the proceedings before the PACLAP Provincial Committee and COSLAP without raising the issue of jurisdiction at those stages. Their appeal to the PACLAP contested the committee’s authority to rule on the validity of the verbal agreement, not its fundamental jurisdiction over the land dispute itself. By raising a new jurisdictional objection only after receiving an adverse decision from COSLAP, petitioners engaged in an undesirable practice condemned by the Court. The principle of estoppel precludes a party from accepting a tribunal’s judgment when favorable and attacking its jurisdiction when adverse. Thus, the COSLAP decision was upheld.