Case Digest (G.R. No. 171101) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Hacienda Luisita, Incorporated (HLI) filed a petition for certiorari, prohibition, and mandamus seeking to nullify Presidential Agrarian Reform Council (PARC) Resolutions No. 2005-32-01 (December 22, 2005) and No. 2006-34-01 (May 3, 2006), which placed HLI’s sugar-cane lands under compulsory coverage after HLI failed to comply with its approved Stock Distribution Plan (SDP). HLI, a spin-off corporation of Tarlac Development Corporation (Tadeco), had submitted an SDP on November 21, 1989 under Section 31 of Republic Act No. 6657 (the Comprehensive Agrarian Reform Law or CARL), offering shares to the 6,296 qualified farmworker-beneficiaries (FWBs). In a July 5, 2011 Decision, the Supreme Court denied HLI’s petition, affirmed the PARC resolutions, and allowed the FWBs the option to remain as HLI stockholders. Upon motions for reconsideration, the Court’s November 22, 2011 Resolution recalled that option, maintained respect for FWBs’ homelots and other benefits, and directed the Lan Case Digest (G.R. No. 171101) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Proceedings
- Petitioners: Hacienda Luisita, Inc. (HLI); petitioners-in-intervention: Luisita Industrial Park Corporation and Rizal Commercial Banking Corporation.
- Respondents: Presidential Agrarian Reform Council (PARC); Agrarian Reform Secretary Pangandaman; farmworker-beneficiary groups (AMBALA; Mallari, Suniga, Andaya, et al.).
- Relief sought: HLI’s certiorari petition to nullify PARC resolutions revoking its Stock Distribution Plan (SDP).
- Background and Prior Resolutions
- 1980–88 litigation: Government sued Tadeco to distribute Hacienda Luisita lands; Court of Appeals dismissed the case in 1988, conditioning dismissal on PARC approval of an SDP.
- November 21, 1989: PARC Resolution No. 89-12-2 approves HLI’s SDP; FWBs become minority shareholders.
- July 5, 2011 Decision: Supreme Court denies HLI’s petition, affirms PARC Resolutions 2005-32-01 and 2006-34-01, but grants original FWBs an option to remain as HLI stockholders or opt for land distribution.
- November 22, 2011 Resolution: On motions for reconsideration, Supreme Court rescinds the FWBs’ option to stay as stockholders, reaffirms SDP revocation, preserves homelot and other benefits, and orders distribution of remaining lands under CARP.
- Motions for Reconsideration
- HLI’s December 16, 2011 Motion: Challenges (a) date of taking for just compensation; (b) revocation of stock-option; (c) return of sale proceeds; (d) entitlement to interest.
- Mallari, et al.’s December 9, 2011 Motion: Argue (a) no CARL requirement for FWBs majority control under stock option; (b) land distribution causes harm; (c) operative-fact doctrine; (d) return of SDOA benefits; (e) alternative date of taking.
Issues:
- What is the appropriate date of taking for determining just compensation?
- Was it proper to revoke the FWBs’ option to remain as HLI stockholders?
- Should proceeds from the sale of the 500-hectare “converted” land and the 80.51-hectare SCTEX parcel be returned to FWBs?
- Are homelots already distributed to FWBs subject to just compensation, and who should receive it?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)