FORTICH vs. CORONA

289 SCRA 624, April 24, 1998

TOPIC:  Finality of Judgement; Administrative Law

DOCTRINE: The orderly administration of justice requires that the judgements/resolutions of a court or quasi-judicial body must reach a point of finality set by the law, rules and regulations; a resolution which substantially modifies a decision after it has attained finality is utterly void. When an administrative agency's decision becomes final and executory and no one has seasonably filed a motion for reconsideration thereto, the said agency has lost its jurisdiction to re-open the case, more so modify its decision.

FACTS:

On March 29, 1996, the Office of the President (OP) issued a decision converting a large parcel of land from agricultural land to agro-industrial/institutional area. Because of this, a group of farmer-beneficiaries staged a hunger strike in front of the Department of Agrarian Reform (DAR) Compound in Quezon City in October 9, 1997. The strike generated a lot of publicity and even a number of Presidential Candidates (for the upcoming 1998 elections) intervened on behalf of the farmers.

Because of this “blackmail”, the OP re-opened the case and through Deputy Executive Secretary Renato C. Corona issued the so-called, “politically motivated”, “win-win” resolution on November 7, 1997, substantially modifying its 1996 decision after it had become final and executory.

ISSUE: WON the “win-win” resolution, issued after the original decision had become final and executory, had any legal effect.

HELD:

No; When the OP issued the Order dated June 23,1997 declaring the Decision of March 29, 1996 final and executory, as no one has seasonably filed a motion for reconsideration thereto, the said Office had lost its jurisdiction to re-open the case, more so modify its Decision. Having lost its jurisdiction, the Office of the President has no more authority to entertain the second motion for reconsideration filed by respondent DAR Secretary, which second motion became the basis of the assailed “Win-Win” Resolution. Section 7 of Administrative Order No. 18 and Section 4, Rule 43 of the Revised Rules of Court mandate that only one (1) motion for reconsideration is allowed to be taken from the Decision of March 29, 1996. And even if a second motion for reconsideration was permitted to be filed in “exceptionally meritorious cases,” as provided in the second paragraph of Section 7 of AO 18, still the said motion should not have been entertained considering that the first motion for reconsideration was not seasonably filed, thereby allowing the Decision of March 29, 1996 to lapse into finality.  Thus, the act of the Office of the President in re-opening the case and substantially modifying its March 29,1996 Decision which had already become final and executory, was in gross disregard of the rules and basic legal precept that accord finality to administrative determinations.

The orderly administration of justice requires that the judgments/resolutions of a court or quasi-judicial body must reach a point of finality set by the law, rules and regulations.  The noble purpose is to write finis to disputes once and for all