#15 Anillo vs COSLAP

Quasi-Judicial Powers

This case emphasized the principle of Hierarchy of Courts, Res Judicata and Procedural Due
Process.

Background Facts: There was a land dispute over properties located at Green Valley Subdivision,
Bacoor, Cavite where herein petitioner claims ownership over the titled properties at the said
subdivision. Petitioner is one of the squatters who claim such ownership, saying that they bought
their land from a certain Don Hermogenes Rodriguez. The squatters built barricades around the
titled properties to prevent the legitimate titled owners from entering the property. A letter of
complaint was filed by the Mayor of Bacoor, Cavite to COSLAP to settle the dispute.

Facts:

 The Commission on Settlement of Land Problems (COSLAP), an administrative agency

exercising quasi-judicial powers, rendered a decision on a land dispute, in favor of the
Homeowners of Green Valley Subdivision, Bacoor, Cavite.
 By virtue of their decision in favor of the complainant homeowners, COSLAP issued a writ
of execution and a writ of demolition to execute the judgment rendered.
 The Squatters and the estate of Rodriguez filed a petition before the Court of Appeals for
the nullification of the said writs of execution and demolition.
 The Court of Appeals affirmed the decision of the COSLAP, thus dismissing the petition of
the estate of Rodriguez and the squatters(Take Note! This is important in the discussion on
Res Judicata).
 Herein petitioner, Concepcion Anillo (Anillo), one of those claiming ownership over the
properties, filed the instant petition for certiorari, prohibition and mandamus, with
temporary restraining order and a writ of preliminary injunction.
 Petitioner even insists that the COSLAP did not acquire jurisdiction over her because she
was not made party in the case filed before COSLAP.

Issue: Whether or not petitioner’s filing of the said petitions is the correct remedy

Held: No.

Ruling:

Hierarchy of Courts

The Supreme Court is a court of last resort and must so remain if it is to satisfactorily perform the
functions assigned to it by the Constitution and immemorial tradition. A direct invocation of the
Supreme Court’s original jurisdiction to issue these extraordinary writs is allowed only when there
are special and important reasons therefor, clearly and specifically set out in the petition.
Petitioner failed to show that such special and important reasons obtain in this case.

It was ruled in the case of Sy vs Coslap: “the COSLAP is among those quasi-judicial agencies
exercising quasi-judicial functions. No convincing reason exists why appeals from the COSLAP
should be treated differently from other quasi-judicial agencies whose orders, resolutions or
decisions are directly appealable to the Court of Appeals under.”
Procedural Due Process in Administrative Proceedings

This shall include the following:

(1) the right to actual or constructive notice of the institution of proceedings which may affect a
respondent’s legal rights;
(2) a real opportunity to be heard personally or with the assistance of counsel, to present
witnesses and evidence in one’s favor, and to defend one’s rights;
(3) a tribunal vested with competent jurisdiction and so constituted as to afford a person
charged administratively a reasonable guarantee of honesty as well as impartiality; and
(4) a finding by said tribunal which is supported by substantial evidence submitted for
consideration during the hearing or contained in the records or made known to the parties
affected

In the Case, petitioner was given constructive notice. COSLAP sent notices to those
claiming ownership over the disputed properties, through registered mail. Petitioner was one of
those who received such registered mail.

Petitioner did not deny the existence of notarized documents regarding the pending
complaints before COSLAP, wherein she was a signatory. She was even represented by a
certain Atty. Pernito who was also the chief legal counsel for the estate of Rodriguez (those
claiming ownership over the lands, together with the squatters)

Res Judicata
The doctrine of res judicata provides that a final judgment on the merits rendered by a court of
competent jurisdiction is conclusive as to the rights of the parties and their privies and constitutes
an absolute bar to subsequent actions involving the same claim, demand, or cause of action.

Under the doctrine of res judicata, the dismissal of said petition before the Court of Appeals
effectively foreclosed the right of petitioner or any person claiming ownership rights under the
Estate of Rodriguez to institute a subsequent action to nullify the proceedings before the
COSLAP.