Facts:

The case involves a dispute over a 144-hectare agricultural 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 known as Del Monte Philippines, Inc. (DMPI), for a ten-year period that expired in April 1994. In October 1991, while the lease was still in effect, the Department of Agrarian Reform (DAR) placed the property under compulsory acquisition, assessing its value at P 2.38 million. NQSRMDC contested this action and was granted a writ of prohibition by the DAR Adjudication Board (DARAB) in February 1992, which ordered the DAR to cease any activities regarding the land until further notice.

Despite this order, the DAR Regional Director issued a memorandum in May 1992 directing the Land Bank to open a trust account for the assessed value and to conduct summary proceedings for just compensation. NQSRMDC objected, leading to furt...

Facts:

1. Land Ownership and Lease

   • The case involves a 144-hectare land in San Vicente, Sumilao, Bukidnon, owned by Norberto Quisumbing, Sr. Management and Development Corporation (NQSRMDC).
   • The land was leased to Del Monte Philippines, Inc. (DMPI) as a pineapple plantation from 1984 to 1994.

2. Compulsory Acquisition by DAR

   • In 1991, the Department of Agrarian Reform (DAR) placed the land under compulsory acquisition for agrarian reform, valuing it at P2.38 million.
   • NQSRMDC resisted this action and obtained a writ of prohibition from the DAR Adjudication Board (DARAB) in 1992, halting DAR's activities on the land.

3. Local Government Reclassification

   • In 1993, the Sangguniang Bayan of Sumilao enacted Ordinance No. 24, reclassifying the land from agricultural to industrial/institutional use.
   • The Bukidnon Provincial Development Council supported this reclassification, citing economic benefits such as job creation and investment opportunities.

4. DAR's Denial of Conversion

   • Despite local support, DAR Secretary Ernesto Garilao denied NQSRMDC's application for land conversion in 1994, citing the land's agricultural value and existing compulsory acquisition notice.
   • NQSRMDC appealed to the Office of the President (OP), which initially approved the conversion in a March 29, 1996 decision.

5. Hunger Strike and "Win-Win" Resolution

   • In 1997, farmer-beneficiaries staged a hunger strike protesting the OP's decision.
   • The OP, through Deputy Executive Secretary Renato Corona, issued a "Win-Win" Resolution on November 7, 1997, modifying its earlier decision. The resolution allowed only 44 hectares for industrial use and ordered the remaining 100 hectares to be distributed to farmer-beneficiaries.

6. Legal Challenges

   • Petitioners (NQSRMDC, Governor Fortich, and Mayor Baula) challenged the "Win-Win" Resolution, arguing that the OP's earlier decision had already become final and executory.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Finality of Judgments

   • Administrative decisions, once final and executory, cannot be modified or reversed except in exceptional circumstances. The Office of the President lost jurisdiction over the case after its March 29, 1996 decision became final.

2. Forum Shopping

   • Forum shopping exists when a party seeks a favorable opinion in another forum after an adverse decision in one. The petitioners' cases were distinct and did not meet the elements of litis pendentia or res judicata.

3. Intervention by Farmer-Beneficiaries

   • Only parties with a present substantial interest, not a mere expectancy, can intervene. The alleged farmer-beneficiaries' interest was contingent on the void "Win-Win" Resolution, making them ineligible to intervene.

4. Void Resolutions

   • A resolution that modifies a final and executory decision is a "lawless thing" and can be ignored or struck down. The "Win-Win" Resolution was issued without legal authority and is therefore null and void.

Conclusion:

The Supreme Court nullified the "Win-Win" Resolution, upheld the finality of the OP's March 29, 1996 decision, and denied the motion for intervention by the alleged farmer-beneficiaries.