Fortich v. Corona
REITERATIONFacts
The Antecedents: This case involves motions for reconsideration filed by respondents and applicants for intervention, seeking to reverse a previous decision that nullified the "win-win" Resolution dated November 7, 1997, issued by the Office of the President (OP). This resolution modified a prior OP Decision dated March 29, 1996, which had declared a 144-hectare property in Sumilao, Bukidnon, under the Comprehensive Agrarian Reform Law (CARL). Procedural History: The OP, in its March 29, 1996 Decision, approved the application for conversion of the land from agricultural to agro-industrial use. The Department of Agrarian Reform (DAR) filed a motion for reconsideration, which was denied for being filed beyond the 15-day reglementary period in an Order dated June 23, 1997. Subsequently, the OP issued the "win-win" Resolution on November 7, 1997, modifying its earlier decision. The Supreme Court, in its April 24, 1998 Decision, nullified this "win-win" Resolution. The Petition: The respondents and applicants for intervention filed separate motions for reconsideration of the Supreme Court's April 24, 1998 Decision, arguing that the "win-win" Resolution was not void, that the proper remedy was a petition for review, that a motion for reconsideration was a condition sine qua non, and that petitioners were guilty of forum-shopping. They also argued that the modification by the OP was a valid exercise of its powers and that intervenors had a right to intervene.
Issue(s)
Whether the "win-win" Resolution dated November 7, 1997, is a void resolution. Whether the March 29, 1996 Decision of the Office of the President had become final and executory. Whether the proper remedy was a petition for review under Rule 43 or a petition for certiorari under Rule 65. Whether a motion for reconsideration is a condition sine qua non before filing a petition for certiorari. Whether the petitioners were guilty of forum-shopping. Whether the intervenors possess a right to intervene in the proceedings. Whether the modification by the Office of the President was a valid exercise of its powers. Whether the power of local government units to reclassify lands is subject to the approval of the Department of Agrarian Reform.
Ruling
The motions for reconsideration are DENIED with FINALITY. The April 24, 1998 Decision of the Supreme Court is AFFIRMED.
Ratio Decidendi
On the void nature of the "win-win" Resolution: The Court reiterated that the "win-win" Resolution of November 7, 1997, was void because it substantially modified a March 29, 1996 Decision of the Office of the President that had long become final and executory. This modification was in gross disregard of the rules and the basic legal precept that accords finality to administrative determinations. The Court emphasized that reopening a case after it has become final and executory, especially through a second motion for reconsideration which is prohibited, constitutes an act in excess of jurisdiction and a flagrant infringement of the doctrine of res judicata. The Court clarified that decisions voided for lack of jurisdiction or grave abuse of discretion are not mere technicalities but adjudications on the merits. The Court enumerated several "fatal violations of the law" committed, namely: (1) the DAR filed its motion for reconsideration of the March 29, 1996 OP Decision way beyond the reglemenatary period; (2) after the said motion for reconsideration was denied for having been filed late, the March 29, 1996 Decision was declared final and executory, but the DAR still filed a second motion for reconsideration which is prohibited by the rules; (3) despite this, the second motion for reconsideration was entertained by herein respondent, then Deputy Executive Secretary Renato C. Corona, and on the basis thereof; issued the "win-win" Resolution dated November 7, 1997, substantially modifying the March 29, 1996 Decision which had long become final and executory; (4) the reopening of the same case through the issuance of the November 7, 1997 "win-win" Resolution was in flagrant infringement of the doctrine of res judicata. These were deemed substantial breaches, not technicalities, as they affected vested rights. On the finality of the March 29, 1996 Decision: The Court affirmed that the March 29, 1996 Decision of the OP had become final and executory. The DAR's motion for reconsideration was denied for having been filed beyond the reglementary period. The Court found that the DAR's explanation for the late filing, attributing it to internal office procedures involving referral to different departments, was not an excusable delay. The Court stressed that internal procedures must not be made subservient to reglementary periods, and that agencies must develop systems to comply with these periods. Therefore, the final and executory character of the OP Decision could no longer be disturbed. On the propriety of the remedy (Certiorari vs. Review): The Court found that the grounds raised by the movants were extensively covered and resolved in its challenged Decision. The issues presented were not of extraordinary import to merit the attention of the Court en banc. The Court reiterated that the issues were matters of no novelty, having been decided in previous cases, and thus did not warrant a departure from the established rulings. On the necessity of a prior motion for reconsideration: The Court reiterated that the grounds raised by the respondents regarding the propriety of petitioners' remedy, the absence of a motion for reconsideration of the "win-win" Resolution before resorting to certiorari, had already been extensively dealt with in its challenged decision and found to be without merit. On forum shopping: The Court stated that the grounds raised concerning forum shopping were extensively covered and resolved in its challenged decision and found to be without merit. On the right to intervene: The Court held that the applicants for intervention did not possess a "certain right" or "legal interest" in the subject matter of the litigation. They admitted to being seasonal farmworkers, not tenants, and the DAR itself had admitted that the subject land was neither tenanted nor validly covered for compulsory acquisition. Under the Constitution, seasonal farmworkers are entitled to a just share of the fruits of the land, not ownership. Therefore, their motion for intervention had to fail as they lacked legal or actual and substantial interest over the subject land. On the validity of the OP's modification and the power of local government units: The Court found that the "win-win" Resolution was issued in excess of jurisdiction and in violation of the principle of finality of administrative determinations. The Court also reiterated its ruling in Province of Camarines Sur, et al. vs. Court of Appeals, which held that local government units do not need the approval of the DAR to convert or reclassify lands from agricultural to non-agricultural use. The Court found that the issues raised by the movants were not novel and had been decided in previous cases, specifically citing Province of Camarines Sur. The Court also noted that the March 29, 1996 OP Decision had thoroughly and properly disposed of the substantive issues, including the nature of the land, the validity of the Notice of Compulsory Acquisition, and the authority of the Sangguniang Bayan to reclassify the land. On the power of local government units to reclassify lands: The Court reiterated its ruling in Province of Camarines Sur, et al. vs. Court of Appeals, which held that local government units do not need the approval of the DAR to convert or reclassify lands from agricultural to non-agricultural use.
Main Doctrine
The "win-win" Resolution dated November 7, 1997, issued by the Office of the President, which substantially modified its March 29, 1996 Decision that had long become final and executory, was void for being issued in gross disregard of the rules and basic legal precept that accord finality to administrative determinations. The late filing of a motion for reconsideration, even if due to internal office procedures, is not an excusable delay and does not justify the reopening of a final and executory decision.