Title
Fortich vs. Corona
Case
G.R. No. 131457
Decision Date
Apr 24, 1998
The Supreme Court nullifies a resolution altering a decision on agricultural land conversion, underscoring the finality of administrative determinations and limiting the Office of the President's authority in such matters.
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Case Digest (G.R. No. 131457)

Facts:

  • The case concerns a 144-hectare agricultural land in San Vicente, Sumilao, Bukidnon, owned by Norberto Quisumbing, Sr. Management and Development Corporation (NQSRMDC).
  • The land was leased to Philippine Packing Corporation, now Del Monte Philippines, Inc. (DMPI), for a ten-year term that ended in April 1994.
  • In October 1991, while the lease was active, the Department of Agrarian Reform (DAR) initiated compulsory acquisition of the property, valuing it at P 2.38 million.
  • NQSRMDC contested this acquisition and received a writ of prohibition from the DAR Adjudication Board (DARAB) in February 1992, halting DAR's actions regarding the land.
  • Despite the writ, the DAR Regional Director issued a memorandum in May 1992 to open a trust account for the assessed value and conduct summary proceedings for just compensation.
  • NQSRMDC objected, leading to further DARAB orders that nullified DAR's actions.
  • In January 1993, the Provincial Development Council of Bukidnon designated the land as part of the Bukidnon Agro-Industrial Zones.
  • In November 1994, DAR denied NQSRMDC's application for land conversion from agricultural to agro-industrial, citing the land's prime agricultural status and absence of a clear compensation package for beneficiaries.
  • NQSRMDC appealed to the Office of the President, which reversed DAR's denial on March 29, 1996, allowing conversion.
  • Following protests from alleged farmer-beneficiaries, the Office of the President issued a "Win-Wina Resolution" on November 7, 1997, modifying the earlier decision to approve only 44 hectares for conversion and ordering distribution of the remaining 100 hectares to farmer-beneficiaries.
  • NQSRMDC and local officials filed a petition to annul the "Win-Wina Resolution," arguing it was issued after the original decision had become final and executory.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of NQSRMDC, nullifying the "Win-Wina Resolution" issued by the Office of the President.
  • The Court determined that the resolution, which significantly altered the earlier decis...(Unlock)

Ratio:

  • The Court highlighted that decisions of the Office of the President become final...continue reading

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