G.R. No. 131457 - Fortich vs. Corona

A hunger strike by alleged farmer-beneficiaries occurred on October 9, 1997, protesting a prior decision by the Office of the President (OP) regarding land conversion.
The OP's March 29, 1996 decision approved the conversion of 144 hectares of agricultural land to agro-industrial use.
The "Win-Win" Resolution issued on November 7, 1997, modified the earlier decision, allowing only 44 hectares for conversion and mandating the distribution of 100 hectares to qualified farmer-beneficiaries.
Petitioners, including the Provincial Governor of Bukidnon and the Municipal Mayor of Sumilao, sought to annul the "Win-Win" Resolution, raising the legal issue of its effect on the final and executory earlier decision.

The land in question is owned by Norberto Quisumbing, Sr. Management and Development Corporation (NQSRMDC) and is covered by a Transfer Certificate of Title.
The land was leased to a multinational corporation for ten years, and the lease expired in April 1994.
The Department of Agrarian Reform (DAR) placed the land under compulsory acquisition in 1991, which NQSRMDC contested.
A series of legal actions ensued, including a writ of prohibition granted to NQSRMDC against DAR's actions.

The Provincial Development Council designated the land as part of the Bukidnon Agro-Industrial Zones in 1993.
The Sangguniang Bayan of Sumilao enacted an ordinance in 1993 to convert the land from agricultural to industrial use, which was approved by various government bodies.
However, DAR denied the conversion application in November 1994, citing the land's status as prime agricultural land and the lack of compensation arrangements for beneficiaries.

NQSRMDC appealed the DAR's denial to the Office of the President, which ultimately reversed DAR's decision on March 29, 1996, allowing the conversion of the land.
Following the OP's decision, DAR filed a motion for reconsideration, which was denied, leading to the issuance of the "Win-Win" Resolution in November 1997.

The "Win-Win" Resolution modified the OP's earlier decision, allowing only a portion of the land for conversion and mandating the distribution of the remaining land to farmer-beneficiaries.
The resolution was issued in response to the hunger strike and subsequent political pressure, which petitioners argued constituted grave abuse of discretion.

Petitioners filed a petition for certiorari and prohibition against the "Win-Win" Resolution, claiming it was illegal and beyond the jurisdiction of the Office of the President.
Respondents opposed the petition, arguing that petitioners should have pursued a different legal remedy and that they engaged in forum shopping.

The court distinguished between errors of judgment and errors of jurisdiction, determining that the petitioners' claims involved an error of jurisdiction.
The court affirmed that the appropriate remedy was a petition for certiorari under Rule 65, as the resolution was alleged to be patently illegal.

The court addressed claims of forum shopping, concluding that the cases filed by petitioners were not identical and did not constitute forum shopping.
The court emphasized that the petition for certiorari sought to nullify the "Win-Win" Resolution, which was distinct from the other cases.