Case Digest (G.R. No. 171101)
Facts:
Hacienda Luisita, Incorporated v. Presidential Agrarian Reform Council, G.R. No. 171101, July 05, 2011, the Supreme Court En Banc, Velasco Jr., J., writing for the Court. Petitioner Hacienda Luisita, Incorporated (HLI) sought relief by a petition for certiorari and prohibition under Rule 65, challenging PARC Resolutions No. 2005-32-01 (Dec. 22, 2005) and No. 2006-34-01 (May 3, 2006) and a DAR Notice of Coverage (Jan. 2, 2006) that recalled/ revoked HLI’s Stock Distribution Plan (SDP) and placed the hacienda under compulsory CARP coverage.The antecedents begin with TADECO’s 1958 acquisition of Hacienda Luisita and assorted government financing conditions contemplating land distribution to tenants. In 1988–1989 TADECO spun off the agricultural portion into HLI, HLI’s capital structure was enlarged, and on May 11, 1989 HLI, TADECO and some 5,848 farmworker-beneficiaries (FWBs) executed the Stock Distribution Option Agreement (SDOA) forming the SDP; PARC approved the SDP by Resolution No. 89-12-2 (Nov. 21, 1989). The SDOA allocated roughly 33.296% of HLI’s outstanding shares (≈118,391,976.85 shares) to FWBs, to be distributed over 30 years on a man‑days basis and to include 3% production sharing and homelots.
Disputes arose about implementation and alleged noncompliance. DAR created a Special Task Force and on Sep. 22, 2005 issued a Terminal Report finding substantial noncompliance and recommending revocation. PARC’s Executive Committee and PARC validated that recommendation and on Dec. 22, 2005 adopted Resolution No. 2005-32-01 recalling the SDP and placing the lands under compulsory CARP coverage; HLI received the DAR Notice of Coverage on Jan. 4, 2006. PARC denied HLI’s motion for reconsideration (Resolution No. 2006-34-01, May 3, 2006).
Meanwhile portions of the 500-hectare converted area had been converted and sold: 300 has. were conveyed to Centennary, sold to Luisita Industrial Park Corporation (LIPCO), and parts later passed to Rizal Commercial Banking Corporation (RCBC) by dacion en pago; 200 has. were sold to Luisita Realty; ~80.51 has. were taken for SCTEX. LIPCO and RCBC successfully moved to intervene in the Supreme Court action claiming innocent‑purchaser ...(Subscriber-Only)
Issues:
- Do the private petitioner‑farmworker groups (Supervisory Group, AMBALA, FARM, ULWU) and intervenors (LIPCO, RCBC) have standing/are real parties‑in‑interest to litigate the DAR/PARC revocation?
- Is Section 31 of R.A. No. 6657 (stock distribution option) unconstitutional as a substitute for direct land ownership under Art. XIII, Sec. 4 of the 1987 Constitution?
- Did PARC have jurisdiction and power to recall/revoke its prior approval of HLI’s SDP?
- Was PARC’s revocation of HLI’s SDP factually and legally justified (grave abuse of discretion)?
- Are the converted parcels sold to LIPCO and RCBC excluded from CARP compulsory coverage because those intervenors are in...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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