Fortich v. Corona
NEW DOCTRINEFacts
The Antecedents: The case involves a dispute over the validity of a "Win-Win" Resolution dated November 7, 1997, which was issued by the Office of the President. Petitioners, including the Provincial Governor of Bukidnon and the Municipal Mayor of Sumilao, Bukidnon, along with NQSR Management and Development Corporation, challenged this resolution. Procedural History: The Supreme Court, in a Resolution dated November 17, 1998, voted two-two on separate motions for reconsideration of its earlier Decision dated April 24, 1998. As a result of the tie, the Decision was deemed affirmed. Respondents and intervenors filed subsequent motions for reconsideration, arguing that the case should be referred to the Court En Banc due to the tie vote, pursuant to Article VIII, Section 4(3) of the Constitution. They also questioned a Resolution dated January 27, 1999, which noted without action the intervenors' motion. The Petition: Respondents and intervenors jointly argued that the tie vote on the motions for reconsideration meant the motions were not effectively resolved and that the case should have been referred to the Court En Banc. They also contended that the issues were of first impression and merited En Banc consideration. Intervenors further asserted their legal standing, claiming they had been issued Certificates of Land Ownership Award (CLOAs) and were qualified beneficiaries.
Issue(s)
Whether a tie vote in the resolution of a motion for reconsideration by a division of the Supreme Court necessitates referral to the Court En Banc. Whether intervenors, who are seasonal farmworkers and recipients of CLOAs, possess the legal standing to intervene in the case, especially considering the nullity of the "Win-Win" Resolution. Whether the issues presented in the motions for reconsideration are of first impression and warrant consideration by the Court En Banc. Whether the present motions for reconsideration constitute a prohibited second motion for reconsideration, and the impact of the finality of judgment on substantive rights.
Ruling
The motions for reconsideration and the plea for referral to the Court En Banc are DENIED with FINALITY. No further motion, pleading, or paper will be entertained in this case.
Ratio Decidendi
On the necessity of referral to the Court En Banc due to a tie vote: The Court clarified that Article VIII, Section 4(3) of the Constitution distinguishes between "cases" and "matters." "Cases" are "decided," while "matters," including motions, are "resolved." The constitutional provision mandates referral to the En Banc only when a "case" is not decided due to a lack of the required votes. In the case of a motion for reconsideration, a tie vote means the motion is not carried, and the original decision stands affirmed. The Court cited its Resolution of November 17, 1998, which affirmed the original decision due to the tie vote on the motion for reconsideration. On the legal standing of intervenors: The Court reiterated that intervenors, being seasonal farmworkers, have no legal or actual substantive interest in owning the land; their right is limited to a just share of its fruits. The issuance of CLOAs to them does not grant requisite standing because these were issued subsequent to the "Win-Win" Resolution, which was declared null and void. No legal rights can emanate from a void resolution. The Court noted that the "Win-Win" Resolution itself stated that qualified beneficiaries were yet to be determined. On whether the issues are of first impression: The Court, citing the opinion of Mr. Justice Antonio M. Martinez, stated that the issues, particularly whether local government units' power to reclassify lands is subject to DAR approval, are not novel. The Court referred to its ruling in Province of Camarines Sur, et al. vs. Court of Appeals, which held that local government units do not need DAR approval for such reclassification. The fact that the original decision was unanimous further supported the view that the issues were not extraordinary. On the prohibition against a second motion for reconsideration and the finality of judgment: The Court found that the present motions were in the nature of a second motion for reconsideration, which is prohibited under Rule 56, Section 4, in relation to Rule 52, Section 2, of the 1997 Rules of Civil Procedure. The Court noted that movants failed to seek prior leave of court and did not show exceptional reasons to justify entertaining such a motion. The arguments presented were deemed rehashes of previously denied motions. The Court emphasized that the nullification of the "Win-Win" Resolution was grounded not merely on a technicality (reglementary period) but on the protection of substantive rights. The finality of the March 29, 1996 Office of the President Decision vested rights in the petitioners and the people who would benefit from the property's development. The Court quoted Mr. Justice Artemio V. Panganiban: "Just as a losing party has the right to file an appeal within the prescribed period, the winning party also has the correlative right to enjoy the finality of the resolution of his/her case."
Main Doctrine
A tie vote in a motion for reconsideration of a division's decision does not necessitate referral to the Court En Banc; such a tie results in the denial of the motion for reconsideration, affirming the original decision. Furthermore, a second motion for reconsideration is generally prohibited unless exceptional circumstances and prior leave of court are shown.