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CARLOS O. FORTICH v. RENATO C. CORONA

FACTS:

The case involves a 144-hectare land located in San Vicente, Sumilao, Bukidnon, owned by the Norberto Quisumbing, Sr. Management and Development Corporation (NQSRMDC). The land was leased to the Philippine Packing Corporation, now Del Monte Philippines, Inc. (DMPI), for a period of ten years. In 1991, during the existence of the lease, the Department of Agrarian Reform (DAR) placed the property under compulsory acquisition and assessed its value. NQSRMDC resisted the DAR's action and sought a writ of prohibition with preliminary injunction from the DAR Adjudication Board (DARAB). The DARAB granted the writ and ordered the DAR and other entities to cease any activity concerning the land. Despite the DARAB order, the DAR Regional Director issued a memorandum directing the Land Bank to open a trust account for the land value and to conduct summary proceedings to determine just compensation. NQSRMDC objected and filed a motion to enforce the DARAB order and nullify the summary proceedings. The DARAB issued a favorable order, nullifying the DAR Regional Director's memorandum and directing the Land Bank to return the claim folder of NQSRMDC's property. The Land Bank complied with the order. The Provincial Development Council designated certain areas, including the subject property, as part of the Bukidnon Agro-Industrial Zones. The Sangguniang Bayan of Sumilao enacted an ordinance converting or re-classifying the land from agricultural to industrial/institutional. The Bukidnon Provincial Land Use Committee and the Bukidnon Provincial Board approved the ordinance. An application for conversion was filed in support of the proposed project.

The case involves the conversion of agricultural land into an agro-industrial area called the Northern Mindanao Regional Agro-Industrial Center (NMRAIC). The Provincial Board approved Resolution No. 94-95, which authorized the development of the NMRAIC. The proposed industrial area includes the Development Academy of Mindanao, Bukidnon Agro-Industrial Park, forest development, and support facilities. The project received favorable recommendations from various government agencies, including the Department of Trade and Industry, Provincial Development Council, Department of Agrarian Reform (DAR), Department of Environment and Natural Resources (DENR), and Department of the Interior and Local Government (DILG). However, despite these recommendations, DAR Secretary Garilao issued an order denying the conversion and instead placed the land under the compulsory coverage of the Comprehensive Agrarian Reform Program (CARP). The order was appealed by Bukidnon Governor Carlos O. Fortich to the Office of the President. In the meantime, the Northern Mindanao Agribusiness and Rural Development Foundation (NQSRMDC), the project proponent, filed a petition with the Court of Appeals to prevent the enforcement of the DAR Secretary's order. The Court of Appeals issued a resolution ordering the parties to observe a status quo pending resolution of the petition.

The case involves a land dispute between the Municipality of Sumilao, Bukidnon and the Northern Mindanao Quadripartite Agro-Industrial Development Corporation (NQSRMDC). In 1995, NQSRMDC filed a petition with the Department of Agrarian Reform (DAR) for the conversion of a parcel of land from agricultural to agro-industrial use. The DAR initially denied the petition, prompting NQSRMDC to file a petition for certiorari with the Court of Appeals. During the pendency of the petition, the Office of the President issued a decision reversing the DAR's denial and approving NQSRMDC's application. However, during this time, without providing just compensation, the DAR caused the cancellation of NQSRMDC's title and transferred it to the Republic of the Philippines. The DAR also issued Certificates of Land Ownership Award (CLOA) and registered them in the name of 137 farmer-beneficiaries. NQSRMDC then filed a complaint with the Regional Trial Court for the annulment and cancellation of the titles.

This case revolves around a disputed land in Quezon City, specifically the property of NQSRMDC. On March 29, 1996, the Office of the President (OP) issued a decision allowing the conversion of the entire 144-hectare property. The Department of Agrarian Reform (DAR) subsequently filed a motion for reconsideration, which was denied by the OP on June 23, 1997. Another motion for reconsideration was filed by the DAR on July 11, 1997. Meanwhile, a writ of preliminary injunction was issued by the Regional Trial Court (RTC) on May 30, 1997, preventing NQSRMDC and 141 others from entering, occupying, or wresting possession of the subject land. This injunction was challenged by alleged farmers through a petition for certiorari and prohibition filed before the Court of Appeals on August 12, 1997. The case also saw some alleged farmer-beneficiaries staging a hunger strike in front of the DAR Compound in Quezon City on October 9, 1997, as a form of protest against the OP decision. Furthermore, on October 10, 1997, individuals claiming to be farmer-beneficiaries of the NQSRMDC property filed a motion for intervention, seeking to set aside the OP decision allowing the conversion of the land.

ISSUES:

  1. What is the legal effect of the "Win-Win" Resolution issued by the Office of the President on its earlier Decision that had already become final and executory?

  2. Whether the petitioners committed a procedural lapse by failing to file a motion for reconsideration of the "Win-Win" Resolution before seeking judicial recourse?

  3. Whether the petitioners are guilty of forum shopping?

  4. Whether the motion for intervention filed by alleged farmer-beneficiaries should be granted?

RULING:

  1. The "Win-Win" Resolution issued by the Office of the President is null and void: The Office of the President had lost its jurisdiction to modify its March 29, 1996 Decision, which had already become final and executory. Thus, the subsequent "Win-Win" Resolution substantially modifying this final Decision was invalid.

  2. The filing of a motion for reconsideration is unnecessary when a questioned resolution is a patent nullity: Since the "Win-Win" Resolution was issued without jurisdiction and after the original Decision had become final, it was considered a nullity, and filing a motion for reconsideration was unnecessary.

  3. The petitioners are not guilty of forum shopping: The cases filed by the petitioners were based on different causes of action and did not involve identical issues. Therefore, they did not violate the rule against forum shopping.

  4. The motion for intervention by alleged farmer-beneficiaries is denied: The movants were merely recommendee farmer-beneficiaries and did not have a present substantial interest over the land in question. Hence, they were not real parties in interest and their motion had no merit.

PRINCIPLES:

  1. Finality of Administrative Determinations: Decisions of quasi-judicial agencies, once final and executory, have the force and binding effect of a final judgment under the doctrine of res judicata.

  2. Prohibition of Second Motions for Reconsideration: Section 7 of Administrative Order No. 18 and Section 4, Rule 43 of the Revised Rules of Court mandate that only one motion for reconsideration is allowed to be taken from a decision. Any subsequent motions are prohibited.

  3. Jurisdictional vs. Judgment Errors: Errors of jurisdiction (acts without, in excess, or with grave abuse of discretion) warrant certiorari, while errors of judgment (within jurisdiction) are reviewable by appeal.

  4. Necessity of Motion for Reconsideration: A motion for reconsideration is not necessary when the assailed resolution or act is considered a patent nullity due to being issued without jurisdiction.

  5. Real Party in Interest: A real party in interest must have a present substantial interest, not mere expectancy or a future interest.

  6. Hierarchy of Courts: A direct invocation of the Supreme Court's original jurisdiction is permissible only for special and important reasons that are clearly and specifically set out in the petition.

  7. Utmost Respect to the Finality of Decisions: Any act that violates the principle of finality, aiming to end disputes once and for all, must be struck down to ensure the orderly administration of justice.