Case Digest (G.R. No. L-26990)
Facts:
Venancio Lim, Sr. v. The Secretary of Agriculture and Natural Resources, G.R. No. L-26990. August 31, 1970, the Supreme Court En Banc, Fernando, J., writing for the Court.The plaintiff-appellee was Venancio Lim, Sr.; the defendants-appellants were the Secretary of Agriculture and Natural Resources, the Director of Lands, the Sugar Quota Administrator and the Sugar Quota Board; Benito Roces intervened as the lessee whose existing lease was in conflict with Lim’s later lease application. The parties stipulated most facts and submitted three documents to the trial court.
In August 1958 the Secretary of Agriculture and Natural Resources (for the Government as lessor) executed a five-year lease in favor of Benito Roces covering planter’s shares of certain sugar-plant marketing allotments in the Mindoro Mill District. Lim sought the same allotments and, after correspondence and an indorsement by the Director of Lands, a second lease was executed on December 8, 1959 by the then Acting Secretary in favor of Lim for a ten-crop-year term (commencing 1963–64) at a higher rental rate. The Roces contract still had four years to run when the Lim contract was executed.
On July 5, 1961 Secretary Cesar M. Fortich revoked the December 8, 1959 lease to Lim, finding the contract "improper, irregular and arbitrary" because it was prematurely executed and because Roces had not been afforded an opportunity to be heard; the order directed reimbursement to Lim of amounts paid and suggested renewing Roces’ contract in due course. Lim filed motions for reconsideration (Aug. 9 and Oct. 16, 1961) and furnished supporting memoranda; the Secretary denied reconsideration on September 12, 1961. Lim appealed to the President (filed Nov. 26, 1962), and the Executive Secretary, Rufino G. Hechanova, acting for the President, affirmed the revocation on August 8, 1963.
Lim then filed an ordinary action in the Court of First Instance of Rizal (Civil Case No. 7813), which annulled the Secretary’s revocation on May 3, 1966, ho...(Subscriber-Only)
Issues:
- Did the Secretary of Agriculture and Natural Resources commit a grave abuse of discretion in revoking the lease granted to Venancio Lim, Sr.?
- Was Lim deprived of procedural or substantive due process by the revocation?
- Did the revocation constitute an unconstitutional impairment of the ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)