Case Summary (G.R. No. 184950)
Applicable Law
The legal framework applicable to this case includes the provisions of the 1987 Philippine Constitution, Republic Act No. 6657 (Comprehensive Agrarian Reform Law), Republic Act No. 3844 (Agricultural Land Reform Code), and various Administrative Orders issued by the Department of Agrarian Reform.
Background Facts
On March 7, 1990, NGEI Coop entered into a lease agreement with FPPI for agricultural land, which included provisions for rental rates and variable payments based on net sales. An addendum was executed on January 29, 1998, extending the lease for an additional 25 years and modifying the benefits for NGEI Coop members. On June 20, 2002, NGEI Coop and Ronquillo filed a complaint for the nullification of the lease agreement and addendum, alleging a lack of authority, failure of approval from stakeholders, and adverse economic terms.
Initial Rulings
The Regional Adjudicator initially ruled in favor of the petitioners on February 3, 2004, declaring the addendum null and void due to lack of authority from NGEI Coop. However, upon FPPI's motion for reconsideration, this decision was reversed on March 22, 2004, citing grounds of prescription and lack of cause of action.
Subsequent Appeals
The petitioners continued to contest the validity of the addendum. An appeal to the Department of Agrarian Reform Adjudication Board (DARAB) affirmed the Regional Adjudicator's ruling, and further appeals led to a decision by the Court of Appeals on May 9, 2008, upholding the validity of the addendum as expressing mutual consent and devoid of any vices.
Grounds for the Petition
The petitioners presented several grounds for their appeal to the Supreme Court, arguing that the Court of Appeals erred in affirming the validity of the addendum, claiming it was executed without proper authority and was contrary to law, morals, and public policy. They also contended that the addendum's rental terms were unconscionable.
Supreme Court’s Findings
The Supreme Court emphasized that the main issue was whether the Court of Appeals committed reversible error in affirming the DARAB's decision. The Court noted that factual issues, including the authority of Dayday to execute the addendum and the validity of the rental terms, were not proper subjects for judicial review under Rule 45 of the Rules of Court, which allows only questions of law to be considered.
Legal Principles Affirmed
The Court reiterated the rule that a contract is binding if entered into with proper authority and conformed to by both parties, highlighting the principle of mutuality. It was established that the addendum was observed and enforced for years, implying acceptance by the petitioners, who failed to demonstrate that the addendum violate
...continue readingCase Syllabus (G.R. No. 184950)
Case Background
- The case is a petition for review on certiorari under Rule 45 of the Rules of Court.
- It involves the petitioners, NGEI Multi-Purpose Cooperative Inc. (NGEI Coop) and Hernancito Ronquillo, against the respondents, Filipinas Palmoil Plantation Inc. (FPPI) and Dennis Villareal.
- The petitioners are challenging the May 9, 2008 Decision of the Court of Appeals and its subsequent October 3, 2008 Resolution, which denied their motion for reconsideration.
Factual Context
- NGEI Coop, a registered agrarian reform workers' cooperative, was awarded 3,996.6940 hectares of agricultural land for palm oil plantations by the Department of Agrarian Reform (DAR) on December 2, 1988.
- On March 7, 1990, NGEI Coop entered a lease agreement with FPPI, establishing an annual fixed rental of P635.00 per hectare, along with a variable rental based on net sales.
- An Addendum to the Lease Agreement was executed on January 29, 1998, extending the lease for another 25 years, and adjusting the economic benefits for NGEI Coop members.
Legal Proceedings
- On June 20, 2002, NGEI Coop and Ronquillo filed a complaint for the Nullification of the Lease Agreement and its Addendum, claiming lack of authority by Antonio Dayday (Chairman of NGEI Coop) to enter into the Addendum and asserting that the agreement deprived them of their rights un