Badua Vs. Cordillera Bodong Administration

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FACTS Spouses Leonor and Rosa Badua allegedly own farm land from which they were forcibly ejected through the decision of the Cordillera Bodong Administration, with the case entitled David Quema v. Leonor Badua. The background of this case reveals that David Quema owns the parcels of land evidenced by Tax Declarations 4997 and 4998. The parcels of land were purchased from Dr. Erotida Valera. Twenty-two (22) years later, he was able to redeem the parcels of land through payment of 10,000 to the vendor's heir, Jessie Macaraeg. Quema was prevented from tilling the land by Rosa Badua. Prompted by such turn of events, David Quema filed a case in the Baranggay Council but failed to have the dispute settled. A judge advised Quema to file his case in the provincial courts. However, Quema did not, and filed it in the tribal court of the Maeng Tribe. Due to several warnings from the tribe, spouses Badua filed a petition for special relief, with the following to be settled: a. That the respondents be enjoined from enforcing the decision of the tribal court in the pending case. b. The respondents be prohibited from usurping judicial power. c. That the legal personality of the Cordillera Bodong Administration be clarified. The Baduas also allege that they were denied due process (or hearing) and that the tribal court has NO jurisdiction over the case, since neither they nor the respondent are members of the Maeng tribe. The respondents contend that the SC has no jurisdiction over the case since the tribal court is NOT a part of the judicial system. ISSUE: Whether the tribal court has jurisdiction over the case. HELD: No. Tribal courts are not a part of the Philippine judicial system which consists of the Supreme Court and the lower courts which have been established by law (Sec. 1, Art. VIII, 1987 Constitution). They do not possess judicial power. Like the pangkats or conciliation panels created by P.D. No. 1508 in the barangays, they are advisory and conciliatory bodies whose principal objective is to bring together the parties to a dispute and persuade them to make peace, settle, and compromise. An amicable settlement, compromise, and arbitration award rendered by a pangkat, if not seasonably repudiated, has the force and effect of a final judgment of a court (Sec. 11, P.D. 1508), but it can be enforced only through the local city or municipal court to which the secretary of the Lupon transmits the compromise settlement or arbitration award upon expiration of the period to annul or repudiate it (Sec. 14, P.D. 1508). Similarly, the decisions of a tribal court based on compromise or arbitration, as provided in P.D. 1508, may be enforced or set aside, in and through the regular courts today.

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