Case Summary (G.R. No. 249011)
Procedural History
• December 11, 1993: Petitioners applied to DAR to convert the land from agricultural to agro-industrial/institutional use.
• November 14, 1994: DAR Secretary Garilao denied conversion and ordered distribution to landless farmers.
• June 7, 1995: DAR denied petitioners’ motion for reconsideration as late.
• March 29, 1996: Executive Secretary Torres reversed DAR, approved full conversion under LGU autonomy.
• June 23, 1997: Executive Secretary deemed March 29 decision final and executory after DAR’s motion was denied for tardiness.
• November 7, 1997: Deputy Executive Secretary Corona issued the “win-win” Resolution modifying the March 29 ruling by allocating 100 hectares for farmer-beneficiaries and 44 hectares for industrial use.
• April 24, 1998: The Second Division struck down the “win-win” Resolution as void, denied intervention and petitioners’ certiorari remedies.
• November 17, 1998: Denial of separate motions for reconsideration filed by respondents and intervenors became final.
Applicable Law
• 1987 Constitution, Art. XIII, Sec. 4 (agrarian reform rights).
• RA 6657 (Comprehensive Agrarian Reform Law).
• Local Government Code (RA 7160) Sec. 20 (LGU power to reclassify land).
• Administrative Order No. 18, Sec. 7 (Office of the President decisions become final after 15 days absent timely motion).
• Rules of Court, Rule 43 (petition for review) and Rule 65 (certiorari).
• Jurisprudence: Province of Camarines Sur v. CA (LGUs need not secure DAR approval to reclassify).
Motions for Reconsideration and Intervention
Respondents’ Grounds:
- The “win-win” Resolution corrected an erroneous ruling; the March 29, 1996 decision was not yet beyond modification.
- Petitioners pursued certiorari instead of the proper remedy of petition for review (Rule 43).
- Motion for reconsideration was a precondition to certiorari.
- Petitioners engaged in forum-shopping to restrain DAR from CARL placement.
Intervenors’ Grounds: - They possess a right to intervene.
- The “win-win” Resolution validly exercised OP powers.
- The resolution addressed substantial issues.
LGU Reclassification Issue
The Division held the LGU power to reclassify agricultural lands does not require DAR approval, citing Province of Camarines Sur v. CA. Section 20 of the Local Government Code grants municipalities and provinces autonomy to convert land use in pursuit of local development. This issue was neither novel nor meriting en banc resolution.
Finality of Administrative Determinations
Under Administrative Order No. 18, Sec. 7, Office of the President decisions become final and executory after 15 days if no motion for reconsideration is timely filed. The March 29, 1996 decision was declared final on June 23, 1997. Any subsequent substantial modification—such as the November 7 “win-win” Resolution—issued beyond the finality period and without exceptional justification, exceeded jurisdiction and violated the principle of finality.
Timeliness of DAR’s Motion for Reconsideration
DAR’s motion for reconsideration of the March 29, 1996 decision was filed beyond the 15-day reglementary period. The explanation that internal routing made timely filing “impossible” failed to justify relaxation of procedural rules. The rules on reglementary periods promote speedy administration of justice and may be liberally interpreted only under justifiable circumstances, which were absent here.
Res Judicata and Jurisdiction
Once final and executory, the March 29, 1996 decision vested substantive rights in petitioners and third parties. The reopening of the same matter via the “win-win” Resolution constituted res judicata and acted
...continue readingCase Syllabus (G.R. No. 249011)
Procedural History
- Petition for certiorari under Rule 65 filed by petitioners to annul the “win-win” Resolution dated November 7, 1997 issued by the Office of the President in O.P. Case No. 96-C-6424
- April 24, 1998 Decision of the Second Division nullified the “win-win” Resolution and denied motions to intervene
- Two separate motions for reconsideration filed by respondents and by applicants for intervention, each seeking reversal of the April 24, 1998 Decision and leave to intervene
- Requests by movants to resolve their motions en banc, invoking “novel questions of law” and issues of “transcendental significance”
Background Facts
- 144-hectare property in San Vicente, Sumilao, Bukidnon leased to Philippine Packing Corporation for pineapple cultivation
- Petitioners (local officials and NQSR Management and Development Corporation) sought conversion from agricultural to agro-industrial use
- Sangguniang Bayan of Sumilao enacted Ordinance No. 24 (March 4, 1993) reclassifying the land to industrial/institutional
- DAR Secretary Garilao denied conversion (Order of November 14, 1994), then denied reconsideration (Order of June 7, 1995)
- Executive Secretary Torres issued Decision of March 29, 1996 affirming LGU reclassification power; DAR’s late motion for reconsideration denied (Order of June 23, 1997)
The “Win-Win” Resolution (November 7, 1997)
- Issued by Deputy Executive Secretary Renato C. Corona upon recommendation of a Presidential Fact-Finding Task Force
- Substantially modified the March 29, 1996 Torres Decision:
- Allocated 100 hectares for distribution to qualified agrarian reform beneficiaries
- Reserved 44 hectares for industrial/commercial development
- Directed the DAR to meticulously determine qualified beneficiaries
- Temporarily took no position on the propriety of intervention by 113 seasonal farmworkers
Issues Raised by Respondents’ Motion for Reconsideration
- Alleged non-void character of the “win-win” Resolution as corrective of an erroneous ruling
- Claim that the proper remedy was petition for review under Rule 43, not certiorari under Rule 65
- Assertion that filing a motion for reconsideration is a condition precedent before certiorari
- Accusation of forum-shopping by petitioners seeking identical relief
Issues Raised by Applicants for Intervention
- Claimed right to intervene based on supposed legal interest
- Defense of the “win-win” Resolution as valid exercise of OP powers
- Argument that the Resolution addressed substantial issues in the controversy