GR 161910; (June, 2008) (Digest)
G.R. No. 161910 & 161930; June 17, 2008
DEPARTMENT OF AGRARIAN REFORM, et al. vs. MA. REGINA I. SAMSON, et al.; LEOLITO EDA, et al. vs. MA. REGINA I. SAMSON, et al.
FACTS
During his lifetime, Enrique T. Samson applied for the exemption of his nine titled parcels of land in Calamba, Laguna, from the Comprehensive Agrarian Reform Program (CARP) coverage. In an undated 1995 Order, the DAR Regional Director granted the exemption, citing Administrative Order No. 10, Series of 1994. In 1997, petitioner-farmers filed an opposition, alleging they received the exemption order only that year and that the lands, despite having a slope of over 18%, contained agricultural developments. Treating this as an appeal, the DAR Secretary issued a new Order in 1998, partially reversing the exemption. This order directed the segregation and CARP coverage of the agriculturally developed portions while exempting the balance. Samson, claiming he was never notified of the farmers’ appeal or the 1998 inspection, elevated the matter to the Office of the President, which affirmed the DAR’s 1998 Order.
ISSUE
Whether the Department of Agrarian Reform Secretary committed grave abuse of discretion in reversing the final and executory 1995 Order of the Regional Director exempting the subject lands from CARP coverage.
RULING
Yes. The Supreme Court affirmed the Court of Appeals and ruled that the DAR Secretary committed grave abuse of discretion. The 1995 exemption order issued by the Regional Director pursuant to his delegated authority under A.O. No. 10-94 had become final and executory. The petitioner-farmers’ opposition, filed only in 1997, was effectively a motion for reconsideration filed well beyond the 15-day reglementary period. Consequently, the DAR Secretary had no jurisdiction to entertain the belated appeal and reverse the final order. The principle of finality of judgment applies with equal force to administrative cases; to allow a reversal based on an out-of-time appeal would violate the rule of law and undermine the stability of judicial and quasi-judicial decrees. The Court emphasized that while the DAR Secretary has control and supervision over regional directors, this power must be exercised within the bounds of procedure and should not be used to revive matters already laid to rest by a final order. The subsequent orders issued by the DAR and the Office of the President were therefore void.