GR 146061; (August, 2006) (Digest)
G.R. No. 146061, August 31, 2006
Sumalo Homeowners Association of Hermosa, Bataan, Petitioner, vs. James T. Litton, et al., Respondents.
FACTS
Respondents, landowners, filed a voluntary offer to sell (VOS) their 213-hectare property in Bataan under the Comprehensive Agrarian Reform Program (CARP) in 1989. The Department of Agrarian Reform (DAR) issued a Notice of Acquisition for only a portion of the land. Subsequently, respondents withdrew their VOS and applied for land use conversion, citing the enactment of the Bases Conversion Act (R.A. 7227), local reclassification ordinances, and a Department of Agriculture finding that the land was not economically suitable for agriculture. The DAR Secretary denied the conversion application in 1996. On appeal, the Office of the President, through Executive Secretary Ruben Torres, issued a Resolution on June 16, 1997 (Torres Resolution) approving the conversion.
Petitioner Association, claiming to represent farmer-beneficiaries, filed a motion for reconsideration. The Office of the President, through a new Executive Secretary, Ronaldo Zamora, issued a Resolution on September 4, 1998 (Zamora Resolution) reversing the Torres Resolution and reinstating the DAR’s denial of conversion. Respondents then appealed to the Court of Appeals, which reversed the Zamora Resolution and reinstated the Torres Resolution. Petitioner Association filed this Petition for Review.
ISSUE
Whether the Court of Appeals correctly reinstated the Torres Resolution, which had approved the land conversion, and reversed the subsequent Zamora Resolution.
RULING
The Supreme Court affirmed the Court of Appeals’ decision. The legal logic centers on the doctrine of finality of administrative decisions. The Torres Resolution of June 16, 1997, from the Office of the President, had become final and executory after the reglementary period to appeal had lapsed without any timely motion for reconsideration being filed by a real party in interest. The Court found that the petitioner Association was not a real party in interest, as it failed to substantiate its claim of representing actual farmer-beneficiaries with a present substantial interest in the land. Its motion for reconsideration before the Office of the President was therefore a mere scrap of paper that did not toll the period of finality.
Consequently, the Zamora Resolution, issued over a year later in September 1998, which substantially altered the final Torres Resolution, was issued in excess of jurisdiction. The Court, citing the precedent in Fortich v. Corona, emphasized the immutability of final judgments and the imperative of respecting the period for appeal to ensure the orderly administration of justice. Since the Torres Resolution had attained finality, it could no longer be validly modified or reversed. Thus, the Court of Appeals correctly reinstated it.