Cordillera Bodong Administration (G.R. No. 92649 February 14, 1991)
Facts: The case concerns a land dispute between the spouses
Leonor and Rosa Badua and a certain David Quema. Both parties claimed ownership of two parcels of land in Villaviciosa, Abra which led to Quema's filing of a case before the Barangay Council. When the Barangay Council failed to settle the dispute, Quema filed it in the tribal court of the Maeng Tribe, (a cultural minority group of Tingguians inhabiting the interior mountain of Villaviciosa, Abra). The Maeng Tribal Court decided to award the parcels of land to Quema and ordered the spouses to pay for the expenses of the case and a fine of P5, 000.00. When the spouses did not immediately vacate the lot, they received a "warning order" from the Zone Commander of the Cordillera People's Liberation Army, the military arm of the Cordillera Bodong Administration. On April 2, 1990, the spouses filed a petition on certiorari and prohibition before the Supreme Court, claiming that the Maeng Tribal Court has neither judicial power nor jurisdiction over the parties.
Issue: Whether or not a tribal court of the Cordillera Bodong
Administration can render a valid and executory decision in a land dispute.
Ruling: The Supreme Court ruled in favor of the petioners.
Citing their ruling in the case of Cordillera Regional Assembly Member Alexander Ordillo vs. COMELEC, the Supreme Court held that since the plebiscite that was held on January 23, 1990 pursuant to Republic Act 6766 was rejected, the creation of the Cordillera Autonomous Region did not come to be. As a logical consequence of that judicial declaration, the Cordillera Bodong Administration, the indigenous and special courts for the indigenous cultural communities of the Cordillera region, and the Cordillera People's Liberation Army as a regional police force or a regional command of the Armed Forces of the Philippines, do not legally exist. Since the Cordillera Autonomous Region did not come into legal existence, the Maeng Tribal Court was not constituted into an indigenous or special court under R.A. No. 6766. Hence, the Maeng Tribal Court is an ordinary tribal court existing under the customs and traditions of an indigenous cultural community and such 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. Thus, they do not possess judicial power.