Case Summary (A.M. No. 07-6-14-CA)
Applicable Law
The case revolves around the legal interpretation of the land conversion as per Republic Act No. 6657 (Comprehensive Agrarian Reform Law) and Section 20 of Republic Act No. 7160 (Local Government Code).
Overview of Events Leading to the Controversy
The controversy stemmed from the Office of the President’s previous decision in OP Case No. 96-C-6424, approving the conversion of 144 hectares of agricultural land into an agro-industrial area on March 29, 1996. The decision was challenged due to its implications on local farmer-beneficiaries who claimed entitlement to the land under the agrarian reform laws.
Legal Issue Presented
The primary legal issue is whether the Win-Win Resolution issued on November 7, 1997, which modified the earlier final and executory decision from March 29, 1996, was legally valid given the principles governing finality in administrative decisions.
Procedural Background
The original administrative interventions led NQSR Management and Development Corporation (NQSRMDC) to file various motions and appeals to contest the actions of the Department of Agrarian Reform (DAR) and enforce decisions protecting their rights as landowners. Subsequent actions by the DAR led to the cancellation of NQSRMDC’s title without just compensation, further aggravating the situation.
Development of the Case
Following the hunger strike and the resulting public outcry, the Office of the President issued the Win-Win Resolution, which only approved a portion of the land for conversion while ordering distribution of the remaining land to farmer-beneficiaries. The petitioners contested this, alleging the resolution was politically motivated and exceeded jurisdictional boundaries.
Legal Analysis of the Win-Win Resolution
The Court determined that decisions made by the Office of the President become final and executory after a designated period unless challenged through a timely motion for reconsideration. In this case, the resolution was found to be a substantial modification of an already final decision. Consequently, the Office of the President lacked the authority to revisit the issue once it had become final, thus rendering the Win-Win Resolution void.
Conclusion
The Supreme Court granted the petition
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Background of the Case
- The case revolves around a 144-hectare land in San Vicente, Sumilao, Bukidnon, owned by the Norberto Quisumbing, Sr. Management and Development Corporation (NQSRMDC).
- The land was previously leased to the Philippine Packing Corporation, now known as Del Monte Philippines, Inc. (DMPI), for ten years, expiring in April 1994.
- The Department of Agrarian Reform (DAR) placed the land under compulsory acquisition in October 1991, assessing its value at P 2.38 million.
- NQSRMDC resisted DAR's action, resulting in a writ of prohibition from the DAR Adjudication Board (DARAB) in early 1992.
Key Developments
- Despite DARAB's order, the DAR Regional Director issued a memorandum in May 1992 to initiate summary proceedings for just compensation, which NQSRMDC opposed.
- The DARAB nullified the DAR's actions, reiterating compliance with its March 31, 1992 order.
- In 1993, the Sangguniang Bayan of Sumilao enacted Ordinance No. 24, reclassifying the land for agro-industrial use, which was supported by various local agencies.
The Office of the President's Decision
- On March 29, 1996, the Office of the President, through Executive Secretary Ruben D. Torres, reversed DAR's prior denial of land conversion, highlighting the economic benefits of converting the land.
- The President noted that while there were irrigation facilities, they did not substantively irrigate the