CARLOS O. FORTICH v. RENATO C. CORONA

FACTS:

The case involves two separate motions for reconsideration filed by respondents and applicants for intervention. The respondents argue that the resolution seeks to correct an erroneous ruling, while the applicants for intervention assert their right to intervene and argue that the modification of the Office of the President's previous decision through the "win-win" Resolution was valid. Both movants raise the issue of whether the power of local government units to reclassify lands is subject to the approval of the Department of Agrarian Reform. The court deems it necessary to write an extended resolution to justify its previous decision due to the wide publicity and media coverage the case has received. The movants request the court to refer their motions to the Court en banc, but the court rejects this request as the issues raised are not of extraordinary importance and have already been decided in previous cases. The court then proceeds to resolve the respondents' motion for reconsideration, wherein they argue against the court's decision to nullify the "win-win" Resolution issued by the Office of the President.

The case involves a motion for reconsideration filed by the Department of Agrarian Reform (DAR) regarding a decision issued by the Office of the President (OP) on March 29, 1996. The OP denied the motion for reconsideration, stating that it was filed late. The DAR argued that the OP's ruling should be corrected because it was based on an erroneous ruling and claimed that the late filing of the motion was excusable due to their office procedure. The court rejected the DAR's arguments, emphasizing the importance of the reglementary period for filing a motion for reconsideration. The court declared the OP's decision as final and executory and invalidated the subsequent "win-win" resolution that modified the previous decision.

The case involves a complaint against the Department of Agrarian Reform (DAR) for disregarding the final and executory decision of the Office of the President (OP) in a land dispute. The movants argue that the case was decided on a mere technicality, but the court emphasizes that a decision rendered without or in excess of jurisdiction is not a mere technicality but a violation of the fundamental principle of finality to administrative determinations. The DAR committed several fatal violations of the law, such as filing a motion for reconsideration beyond the reglementary period and filing a second motion for reconsideration despite the first motion being denied for being filed late.

ISSUES:

  1. Whether the violations committed by the DAR in filing the motion for reconsideration and the second motion for reconsideration are mere technicalities or substantial breaches of the law.

  2. Whether the reopening of the case through the "win-win" Resolution is a grave breach of the doctrine of res judicata.

  3. Whether the issue of procedural lapses should have been raised and resolved at the administrative level.

  4. Whether the grounds raised by respondents in their motion for reconsideration concerning the propriety of petitioners' remedy, absence of a motion for reconsideration of the "win-win" Resolution, and forum shopping lack merit.

  5. Whether the applicants for intervention have the legal interest to intervene in the proceedings.

  6. Whether the applicants for intervention have a legal or substantial interest over the subject land.

  7. Whether the applicants for intervention have the right to own the subject land.

  8. Whether the factual findings of administrative agencies are binding and conclusive on the Court

  9. Whether the proposed development project on the disputed land is for the benefit of the majority

  10. Whether the Motion for Reconsideration and the applicants for intervention should be denied.

RULING:

  1. The violations committed by the DAR in filing the motion for reconsideration and the second motion for reconsideration are substantial breaches of the law, not mere technicalities.

  2. The reopening of the case through the "win-win" Resolution is a grave breach of the doctrine of res judicata.

  3. The issue of procedural lapses should have been raised and resolved at the administrative level.

  4. The grounds raised by respondents in their motion for reconsideration lack merit.

  5. The applicants for intervention do not have the legal interest to intervene in the proceedings.

  6. The applicants for intervention must fail in their motion for intervention as they have no legal or substantial interest over the subject land. The equitable distribution of land is a right given to landless farmers and regular farmworkers to own the land they till, while seasonal farmworkers are only entitled to a just share of the fruits of the land.

  7. The applicants for intervention, being seasonal farmworkers without the right to own the land, are not qualified beneficiaries of the subject land.

  8. The Court held that factual findings of administrative agencies, which have acquired expertise in their field, are binding and conclusive on the Court. The Office of the President, being presumed to be most competent in matters falling within its domain, has the authority to make findings of fact.

  9. The Court found that the proposed development project on the disputed land is for the benefit of the majority. The project includes the establishment of educational institutions, agro-industrial facilities, forest development, and support facilities, which will provide economic benefits, employment opportunities, and raise the income of the people in the community.

  10. The April 24, 1998 Decision of the Court denying the Motion for Reconsideration and the application for intervention is affirmed with finality.

PRINCIPLES:

  • A decision/resolution/order of an administrative body, court, or tribunal rendered without or in excess of jurisdiction, or with grave abuse of discretion, is not a mere technicality but an essential requirement of law. (jurisdiction, grave abuse of discretion)

  • The reopening of a case through a resolution despite being final and executory is a grave breach of the doctrine of res judicata. (res judicata)

  • Procedural lapses should be raised and resolved at the administrative level and cannot be questioned for the first time before a higher court. (procedural lapse)

  • The right to intervene in a case requires a "certain right" or "legal interest" in the subject matter of the litigation, which must be actual, substantial, material, direct, and immediate. (right to intervene, legal interest)

  • The equitable distribution of land is a right given to landless farmers and regular farmworkers to own the land they till.

  • Seasonal farmworkers are entitled to a just share of the fruits of the land but do not have the right to own the land.

  • Intervention in a case is only allowed if the applicants have legal or substantial interest over the subject matter.

  • Procedural lapses in identifying or reclassifying land for agro-industrial purposes should not defeat the autonomy of local government units in managing their local affairs.

  • Factual findings of administrative agencies are binding and conclusive on the Court.

  • The interest of justice is invoked in favor of the pro-poor and beneficial effects of development projects.

  • Government support and recommendations, as well as the endorsement of affected communities, are factors that may be considered in determining the benefits of a proposed project.

  • The Court has the power to deny a Motion for Reconsideration and applications for intervention.

  • Once a decision has been rendered with finality, the Court cannot entertain further motions or applications regarding the same case.