question archive What are the facts, issue and ruling of G
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What are the facts, issue and ruling of G.R. No. Cooperative Development Authority, Petitioner, Vs. Dolefil Agrarian Reform Beneficiaries Cooperative, Inc., Esmeraldo A. Dublin, Alicia Savarez, Edna Ureta, Et Al., Respondents, May 29, 2002 Philippine constitution law it case digest
Answer:
Authority of the Cooperative Development Authority
FACTS:
In 1997, the Cooperative Development Authority (CDA) received several complaints from members of Dolefil Agrarian Reform Beneficiaries Cooperative, Inc (DARBCI), an agrarian reform cooperative, for mismanagement and/or misapproriation of funds of DARBCI by the then incumbent officers and members of the board of directors of the said cooperative. Acting on the complaint, CDA issued an order, temporarily freezing the funds of DARBCI and creating a management committee to manage the affairs of the said cooperative. This prompted the directors of DARBCI to file before RTC of Polomok, South Cotabato a Petition for Certiorari with a prayer for writ of Preliminary Injunction, damages and attorney's fees against CDA and its officers, primarily on questioning the authority and jurisdiction of the CDA in interfering and resolving intra-cooperative complaints or disputes within cooperatives, particularly the CDA's issuance of freeze order and creation of management committee which would run the affairs of DARBCI. Both RTC Polomolok and Court of Appeals ruled in favor of the officers of DARBCI, nullifying the orders of CDA and permanently enjoining them from interfering with the affairs of DARBCI. Thus, the present petition.
Petitioner CDA argues that they have quasi-judicial authority to decide intra-cooperate disputes, averring that when an administrative agency is conferred with quasi-judicial powers and functions, all controversies relating to the subject matter pertaining to its specialization are deemed to be covered within the jurisdiction of the said administrative agency. The courts will not interfere in matters which are addressed to the sound discretion of government agencies entrusted with the regulation of activities undertaken upon their special technical knowledge and training. CDA further maintains that since it is granted with authority to conduct hearings and possess contempt powers, it necessarily means that it is granted with quasi-adjudicatory powers of resolving intra-cooperative disputes.
On the other hand, respondent officers of DARBCI posit that contrary to the claim of CDA, the powers, functions and responsibilities of the CDA show that it was merely granted regulatory or supervisory powers over cooperatives in addition to its authority to mediate and conciliate between parties involving the settlement of cooperative disputes.
ISSUE: Whether or not CDA is empowered under the law with quasi-judicial authority to adjudicate intra-cooperative disputes
RULING: CDA IS NOT VESTED WITH QUASI-JUDICIAL AUTHORITY TO ADJUDICATE INTRA-COOPERATIVE DISPUTES.
It is a fundamental rule in statutory construction that when the law speaks in clear and categorical language, there is no room for interpretation, vacillation or equivocation - there is only room for application. It can be gleaned from the above-quoted provision of R.A. No. 6939 that the authority of the CDA is to discharge purely administrative functions which consist of policy-making, registration, fiscal and technical assistance to cooperatives and implementation of cooperative laws. Nowhere in the said law can it be found any express grant to the CDA of authority to adjudicate cooperative disputes. At most, Section 8 of the same law provides that "upon request of either or both parties, the Authority shall mediate and conciliate disputes with a cooperative or between cooperatives" however, with a restriction "that if no mediation or conciliation succeeds within three (3) months from request thereof, a certificate of non-resolution shall be issued by the commission prior to the filing of appropriate action before the proper courts". Being an administrative agency, the CDA has only such powers as are expressly granted to it by law and those which are necessarily implied in the exercise thereof.
Petitioner CDA, however, insists that its authority to conduct hearings or inquiries and the express grant to it of contempt powers under Section 3, paragraphs (g) and (o) of R. A. No. 6939, respectively, necessarily vests upon the CDA quasi-judicial authority to adjudicate cooperative disputes. A review of the records of the deliberations by both chambers of Congress prior to the enactment of R.A. No. 6939 provides a definitive answer that the CDA is not vested with quasi-judicial authority to adjudicate cooperative disputes.
The decision to withhold quasi-judicial powers from the CDA is in accordance with the policy of the government granting autonomy to cooperatives. Acknowledging the role of cooperatives as instruments of national development, the framers of the 1987 Constitution directed Congress under Article XII, Section 15 thereof to create a centralized agency that shall promote the viability and growth of cooperatives. Thus, CDA was born through the enactment of Republic Act 6939. However, CDA only possess powers which are listed in its organic law (RA 6939). The authority to conduct hearings or inquiries and the power to hold any person in contempt may be exercised by the CDA only in the performance of its administrative functions under R.A. No. 6939. Consequently, the Supreme Court hold and rule that the CDA is devoid of any quasi-judicial authority to adjudicate intra-cooperative disputes and more particularly disputes as regards the election of the members of the Board of Directors and officers of cooperatives.