G.R. No. L-44546 - Adille vs. Court of Appeals

CMU is a state-run agricultural educational institution located in Musuan, Bukidnon.
Its evolution began as a farm school in early 1910, later becoming the Bukidnon National Agricultural High School, and eventually a college and full-fledged university.
On January 16, 1958, President Carlos P. Garcia issued Proclamation No. 476, reserving 3,080 hectares for the future campus of the Mindanao Agricultural College (forerunner of CMU) under OCT Nos. 160, 161, and 162.
During the cadastral proceedings, parts of the originally claimed 3,401 hectares were reduced due to ancestral land claims by cultural communities.

The university experienced significant growth—from a student population of less than 3,000 in the early 1960s to approximately 13,000 by 1988.
To accommodate its expanding enrollment, CMU improved and expanded its facilities through a mix of government appropriations and self-help measures.
Early land use planning, including a 1975 plan and subsequent revisions, allocated portions of the total land for purposes such as livestock, upland crops, campus facilities, irrigated rice, watershed and forest reservation, among others.

In 1984, CMU adopted the "Kilusang Sariling Sikap Program" (CMU-KSSP), under which faculty and staff leased land to cultivate lowland rice.

The written contract expressly stated that no landlord–tenant relationship existed.
A nominal service fee and land use fee were collected by CMU in return for technical assistance and training.

Under CMU-Income Enhancement Program (CMU-IEP) launched in 1986, the university entered into a tripartite Memorandum of Agreement with the CMU Integrated Development Foundation (CMU-IDF) and groups of employees (selda).

The program provided 4 to 5 hectares for a one-year period, payable through a service fee and a land rental fee.
The arrangement similarly stressed the nonexistence of any tenant–landlord relationship.
Following the discontinuation of the Agri-Business Management and Training Project due to losses, some former employees were allowed to participate under an addendum contract.
Contracts had explicit terms prohibiting residential use and the establishment of a tenancy or sharecropping arrangement.

The Barangay complainants, operating as the Bukidnon Free Farmers and Agricultural Laborers Organization (BUFFALO), filed a complaint before the Department of Agrarian Reform (DAR) claiming tenant status.

Complainants included CMU personnel, former employees, and hired laborers associated with the livelihood programs.
They alleged being landless peasants or tenants occupying parts of the CMU land.

The DAR Adjudication Board (DARAB) found that under both the "Kilusang Sariling Sikap Program" and CMU-IEP, no landlord–tenant relationship existed.

The complainants were determined not to be share tenants, leaseholders, or landless peasants.
Despite this, the DARAB ordered the segregation of 400 hectares of CMU land to be included in the Comprehensive Agrarian Reform Program (CARP).

The Court of Appeals affirmed the DARAB decision, which was later subjected to a Petition for Review on Certiorari by CMU under Rule 65.

CMU’s original land reservation was established to support its long-term objectives as an agricultural school—with potential for future expansion.
The 400 hectares in question were part of a larger plan where land use was divided into livestock, upland crops, campus sites, irrigated rice, and other components.
Prior contracts, such as with the Philippine Packing Corporation, were entered into before the enactment of R.A. 6657 and were aligned with the university’s research and educational purposes.
The decision to segregate the 400 hectares was based on the alleged fact that this land was "not directly, actually and exclusively used for school sites" because of a prior management arrangement.

Whether the DARAB had the legal jurisdiction to hear and decide on the agrarian reform case filed by the complainants.
Whether the decision to segregate 400 hectares from the CMU land reservation falls within the scope of the Comprehensive Agrarian Reform Program.

Whether the agreements under the CMU livelihood programs (both CMU-KSSP and CMU-IEP) constituted landlord–tenant relationships or any form of tenancy.
Whether complainants, including faculty, staff, and former employees, can be factually and legally recognized as landless peasants eligible for agrarian reform benefits.

Whether the segregation order of the 400 hectares exceeds the authority and posed an overreach beyond the relief sought by the complainants.
Whether the quasi-judicial body (DARAB), by ordering a segregation of land not utilized directly for educational purposes, committed grave abuse of discretion.

Whether the Court of Appeals erred in dismissing CMU’s petition and in affirming the decision rendered by the DARAB.
Whether the appellate tribunal improperly substituted its judgment regarding land utilization needs of the CMU.