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 (Lot 1) of the surveyed land to his son-in-law, Guillermo Banaga, who filed a free patent application for it. Daproza protested this application and filed his own for the remaining lots. The Bureau of Lands failed to resolve the conflicting claims. Daproza then sought intervention from the Presidential Action Committee on Land Problems (PACLAP), whose Provincial Committee, after investigation, upheld the verbal agreement and ordered the segregation of a portion for Daproza. This resolution was affirmed by the Commission on the Settlement of Land Problems (COSLAP), which succeeded PACLAP.
ISSUE
Whether the PACLAP/COSLAP had jurisdiction over the land dispute, or if jurisdiction properly belonged to the Bureau of Lands or the regular courts.
RULING
The Supreme Court upheld COSLAP’s jurisdiction and dismissed the petition. The legal logic rests on two primary grounds: statutory authority and estoppel. Firstly, at the time the PACLAP Provincial Committee exercised jurisdiction in 1978, it was empowered under Presidential Decree No. 832 to assume jurisdiction over land disputes of critical nature or involving occupants and cultural minorities. The Court found the dispute, involving conflicting public land applications and allegations of bad faith, to be sufficiently critical. The subsequent enactment of Executive Order No. 561 in 1979, which more explicitly defined COSLAP’s jurisdiction, could not retroactively divest the PACLAP of jurisdiction it had validly exercised. Secondly, and decisively, the petitioners were estopped from challenging jurisdiction. They actively participated in the PACLAP/COSLAP proceedings without raising the objection that the Bureau of Lands had exclusive jurisdiction. Their appeal to the COSLAP only contested the committee’s authority to rule on the validity of the verbal agreement, a different jurisdictional issue. The Court condemned the practice of submitting to a tribunal’s authority and then attacking it only after an adverse decision, applying the principle from Tijam v. Sibonghanoy to bar the belated challenge. Thus, the COSLAP decision was affirmed.
