Case Digest (G.R. No. 184950)
Facts:
NGEI Multi-Purpose Cooperative Inc. and Hernancito Ronquillo v. Filipinas Palmoil Plantation Inc. and Dennis Villareal, G.R. No. 184950, October 11, 2012, Supreme Court Third Division, Mendoza, J., writing for the Court.
On December 2, 1988, petitioner NGEI Multi-Purpose Cooperative Inc. (NGEI Coop) was awarded 3,996.6940 hectares by the Department of Agrarian Reform (DAR) for palm oil plantations in Agusan del Sur. On March 7, 1990, NGEI Coop leased the land to respondent Filipinas Palmoil Plantation, Inc. (FPPI), under a contract providing a fixed annual rental of P635.00 per hectare plus a variable component based on net sales.
On January 29, 1998, the parties executed an Addendum extending the lease from January 1, 2008 to December 31, 2032, keeping the P635.00 per-hectare annual rental but establishing a schedule of increased per-hectare economic benefits to bona fide cooperative members. The Addendum was signed by Antonio Dayday as Chairman of NGEI Coop and by respondent Dennis Villareal for FPPI, and was witnessed by a DAR undersecretary.
On June 20, 2002, petitioners filed before the DAR Adjudication Board (DARAB) Regional Adjudicator a complaint to nullify the Addendum (DARAB Case No. XIII (03)176), alleging Dayday lacked authority to sign, that the Addendum was not approved by the Presidential Agrarian Reform Council (PARC) Executive Committee as required by DAR A.O. No. 5, Series of 1997, that the terms were onerous and contrary to agrarian law and policy (including R.A. No. 6657, as amended by R.A. No. 7905), and that the lease deprived beneficiaries of tilling their land.
The Regional Adjudicator initially declared the Addendum null and void in a February 3, 2004 Decision, but on reconsideration reversed that finding in an Order dated March 22, 2004, dismissing the complaint on grounds of prescription and lack of cause of action and finding the Addendum valid and binding. A motion for reconsideration was denied on April 28, 2004.
On appeal to the DARAB Central Office, the DARAB rendered a decision dated October 9, 2006 affirming the Regional Adjudicator’s March 22, 2004 Order and denying the appeal for lack of merit.
Petitioners then appealed to the Court of Appeals via a petition for review under Rule 43. On May 9, 2008 the Court of Appeals (CA) affirmed the validity and binding effect of the Addendum, finding the parties freely agreed to its terms and that the DARAB’s factual findings were supported by substantial evidence (citing Sps. Joson v. Mendoza). The CA denied petitioners’ motion for reconsideration in an October 3, 2008 Resolution.
Petitioners filed a petition for review on certiorari under Rule 45 with the Supreme Court, challenging the CA’s affirmation of DARAB’s decision on grounds that the Addendum was void ab initio (for lack of authority/ratification and violations of A.O. No. 5 and ag...(Subscriber-Only)
Issues:
- In a petition for review under Rule 45, may this Court re-evaluate the factual findings of the DARAB and the Court of Appeals?
- Was the Addendum to the lease void ab initio for want of authority, lack of ratification, and for being contrary to law, morals, good customs or public policy?
- Are the factual findings of the DARAB and the CA that sustained the Addendum supported by substantial evidence and free from grave abuse of discretion?
- Had petitioners’ cause of action to nullify the Addendum prescribed un...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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