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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