Title
Department of Agrarian Reform vs. Philippine Communications Satellite Corp.
Case
G.R. No. 152640
Decision Date
Jun 15, 2006
In the case of Department of Agrarian Reform v. Philippine Communications Satellite Corp., the Supreme Court affirms the exemption of a parcel of land owned by PHILCOMSAT from the Comprehensive Agrarian Reform Program (CARP) due to its designation as a security zone under Presidential Decree No. 1845, stating that the protection of PHILCOMSAT's operations is necessary for national defense.
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Case Digest (G.R. No. 152640)

Facts:

  • The case involves a parcel of land owned by the Philippine Communications Satellite Corporation (PHILCOMSAT) in Pinugay, Baras, Rizal.
  • This land contains the Philippine Space Communications Center (PSCC) and a satellite earth station, which is a crucial communications gateway for the Philippines.
  • The surrounding area, cultivated by local farmers with fruit trees, rice, and corn, was declared a security zone under Presidential Decree (P.D.) No. 1845 on April 30, 1982, and later amended by P.D. No. 1848 on July 29, 1982.
  • The security zone encompasses a three-kilometer radius around the satellite earth station, totaling 5,654 hectares, including 700 hectares owned by PHILCOMSAT.
  • In 1992, the Department of Agrarian Reform (DAR) issued a Notice of Coverage to PHILCOMSAT, indicating the land would be placed under the Comprehensive Agrarian Reform Program (CARP).
  • PHILCOMSAT sought an exemption from CARP, arguing the land was essential for national defense and operational expansion.
  • DAR rejected the exemption application, leading PHILCOMSAT to file a petition for review with the Court of Appeals, which ruled in favor of PHILCOMSAT.
  • DAR then filed a petition for review on certiorari with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, declaring the subject landholdings of PHILCOMSAT exempt from CARP coverage due to their ...(Unlock)

Ratio:

  • The Supreme Court held that P.D. No. 1845 and P.D. No. 1848, issued before the Comprehensive Agrarian Reform Law of 1988, established the area around PHILCOMSAT's satellite earth station as a security zone to ensure its security and uninterrupted operation, given its vital role in national telecommunications and development.
  • The decrees granted the Ministry of National Defense control and administration over the security zone, including the authority to determine occupancy and land use.
  • The Court emphasi...continue reading

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