Case Digest (G.R. No. 171101) Core Legal Reasoning Model
Facts:
The case involves Hacienda Luisita, Incorporated (HLI) as the petitioner, and the Presidential Agrarian Reform Council (PARC), the Department of Agrarian Reform (DAR), and various farmworkers' groups as respondents. The controversy centers on the approved Stock Distribution Plan (SDP) of HLI, which was sanctioned by PARC in 1989 under RA 6657, the Comprehensive Agrarian Reform Law (CARL). The SDP provided that instead of direct land distribution, qualified farmworker-beneficiaries (FWBs) of Hacienda Luisita would be given shares of stock in HLI proportional to the agricultural land devoting in relation to the corporation's total assets.
Due to alleged violations by HLI, PARC revoked its approval of the SDP in 2005, placing Hacienda Luisita’s lands under compulsory coverage for land redistribution pursuant to CARP. The farmworkers and other private respondents contested the nullification and execution of the revocation. HLI and its subsidiaries, including Luisita Industr
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Case Digest (G.R. No. 171101) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner: Hacienda Luisita, Inc. (HLI), with intervention by Luisita Industrial Park Corporation (LIPCO) and Rizal Commercial Banking Corporation (RCBC).
- Respondents: Presidential Agrarian Reform Council (PARC), Secretary Nasser Pangandaman of the Department of Agrarian Reform (DAR), Alyansa ng mga Manggagawang Bukid ng Hacienda Luisita (AMBALA), private respondents including Rene Galang, Noel Mallari, Julio Suniga, Supervisory Group of HLI, and Windsor Andaya.
- Context: Conflict stemming from the Comprehensive Agrarian Reform Program (CARP) coverage of Hacienda Luisita lands and the validity and implementation of the Stock Distribution Plan (SDP) and Stock Distribution Option Agreement (SDOA) involving HLI and its farmworker-beneficiaries (FWBs).
- Procedural History
- On July 5, 2011, the Supreme Court promulgated a decision denying HLI’s petition and affirming PARC Resolutions revoking approval of the SDP, with modification granting FWBs option to remain as stockholders or opt for land distribution.
- Following this decision, various parties filed motions for reconsideration and clarification raising multiple issues including distribution of proceeds from sales of converted lands, constitutionality of a key provision in RA 6657, applicability of the doctrine of operative fact, just compensation, and legitimacy of sales to third parties.
- Key Contentions
- HLI argued it is improper to distribute unspent proceeds from sale of converted land to FWBs because these funds are corporate assets, and also contested the date of “taking” for just compensation purposes.
- PARC and DAR contested the application of the operative fact doctrine, arguing that a positive law mandates land distribution upon revocation of the SDP.
- AMBALA and FARM raised constitutional challenges against Section 31 of RA 6657 and disputed the application of the operative fact doctrine and the option given to FWBs regarding stock retention or land distribution.
- Issues concerning the validity of the conversion of agricultural lands and the characterization of LIPCO and RCBC as innocent purchasers were also raised.
- Mallari, et al., contended full compliance with distribution of homelots and that shares were properly allocated, thus questioning the grounds for revocation of the SDP.
- Rene Galang and AMBALA sought total land redistribution, opposing the option to remain as stockholders and challenging the status of certain third-party purchasers.
Issues:
- Applicability of the Doctrine of Operative Fact in the Case of the Revocation of the SDP Approval.
- Constitutionality of Section 31 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law).
- Proper Coverage of Agricultural Lands under Compulsory Acquisition following SDP Revocation.
- Validity of the Conversion of Portions of Hacienda Luisita Agricultural Lands into Commercial/Industrial Uses.
- Status of Luisita Industrial Park Corporation (LIPCO) and Rizal Commercial Banking Corporation (RCBC) as Innocent Purchasers.
- Distribution and Utilization of Proceeds from Sale of Converted Agricultural Lands and SCTEX Lot.
- Proper Date for Reckoning Just Compensation.
- Legality of Sale and Transfer Restrictions of Awarded Lands under RA 6657.
- Grounds and Justification for PARC’s Revocation of HLI’s Stock Distribution Plan.
- Control Over Agricultural Lands by Qualified Farmworker-Beneficiaries in HLI and Consequences of Option to Remain Stockholders.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)