Case Digest (A.M. No. RTJ-21-014) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Fortich, et al. v. Corona, et al. (G.R. No. 131457, August 19, 1999), petitioners Hon. Carlos O. Fortich, Provincial Governor of Bukidnon; Hon. Rey B. Baula, Municipal Mayor of Sumilao, Bukidnon; and NQSR Management and Development Corporation challenged the validity of the Department of Agrarian Reform’s “Win-Win” Resolution of November 7, 1997, which purported to award Certificates of Land Ownership Award (CLOAs) to seasonal farmworkers on a large plantation in Bukidnon. After the Office of the President’s March 29, 1996 decision became final, petitioners secured possession of the property and sought judicial affirmation of the DAR’s lack of authority to reclassify agricultural lands without local government unit approval. In the April 24, 1998 Decision, the Second Division of the Supreme Court denied intervenors’ motion to intervene, granted petitioners’ petitions, and set aside the DAR resolution. Intervenors and respondents Renato C. Corona (Deputy Executive Secretary) a Case Digest (A.M. No. RTJ-21-014) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- On April 24, 1998, the Special Second Division rendered a decision disposing of petitions filed by the Provincial Governor of Bukidnon, the Municipal Mayor of Sumilao, and NQSR Management and Development Corporation against certain Department of Agrarian Reform (DAR) orders.
- Respondents and intervenors moved for reconsideration of that decision. On November 17, 1998, the Second Division voted 2–2 on those motions, and, by operation of Rule 52, Section 2 and Rule 56, Section 4 of the 1997 Rules of Civil Procedure, deemed the motions denied and the April 24 decision affirmed.
- Subsequent Motions and Resolutions
- Intervenors filed, on December 3, 1998, a “Motion for Reconsideration with Motion to Refer the Matter to the Court En Banc,” which was noted without action on January 27, 1999, on grounds that (a) intervenors lacked legal personality after denial of their leave to intervene, and (b) the motion was a prohibited second motion for reconsideration.
- Respondents likewise filed, on December 2 and 3, 1998, a “Motion for Reconsideration of the Resolution dated November 17, 1998 and for Referral of the Case to this Honorable Court En Banc,” accompanied by proof of mailing.
- Parties’ Contentions
- Movants asserted that a 2–2 tie in the Second Division required automatic referral of the case to the Supreme Court sitting en banc under Article VIII, Section 4(3) of the 1987 Constitution.
- They argued that the issues raised—primarily the DAR’s authority over LGU land reclassification and the validity of the “Win-Win” Resolution—were of first impression deserving full-court consideration.
- Intervenors further claimed real-party-in-interest status based on certificates of land ownership award (CLOAs) and identification as qualified beneficiaries by the DAR.
Issues:
- Does a 2–2 tie vote on motions for reconsideration by a Supreme Court division mandate referral of the case to the Court en banc under Article VIII, Section 4(3) of the Constitution?
- Are the respondents’ and intervenors’ December 1998 motions second, prohibited motions for reconsideration under Rule 56, Section 4 in relation to Rule 52, Section 2 of the 1997 Rules of Civil Procedure?
- Do intervenors possess the requisite legal standing to participate as real parties in interest?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)