Case Digest (G.R. No. 179594) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Diamond Farms, Inc. v. Diamond Farm Workers Multi‐Purpose Cooperative, G.R. No. 192999, decided July 23, 2012 under the 1987 Constitution, Diamond Farms, Inc. (“petitioner”), a commercial banana‐farming corporation owning 1,023.8574 hectares in Carmen, Davao, saw 958.8574 hectares of its land initially deferred under CARP. A Production and Profit Sharing (PPS) Scheme was approved by DAR Secretary Garilao on November 3, 1992, and on February 14, 1995 the land was placed under CARP. Of the 958 hectares, 698.8897 hectares were awarded to the Diamond Agrarian Reform Beneficiaries Multi‐Purpose Cooperative, while petitioner retained management of 277.44 hectares, including a 109.625-hectare parcel. On November 23, 1999, petitioner’s titles to that parcel were cancelled and replaced by TCTs in the Republic’s name after deposit of compensation. On August 5, 2000, DAR identified 278 agrarian reform beneficiaries (mostly members of respondent DFWMPC), and on October 26, 2000 it issued Case Digest (G.R. No. 179594) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Diamond Farms, Inc. (Petitioner) is a corporation engaged in commercial banana farming; owned 1,023.8574 hectares in Carmen, Davao.
- Of this, 958.8574 hectares were deferred under the Comprehensive Agrarian Reform Program (CARP). After deferment was lifted on February 14, 1995, 698.8897 ha were awarded to Diamond Agrarian Reform Beneficiaries Multi-Purpose Cooperative, while petitioner retained 277.44 ha, including 109.625 ha.
- CARP Proceedings and Title Transfers
- November 3, 1992: DAR approved a Production and Profit Sharing (PPS) Scheme under Section 32, Republic Act No. 6657 (CARL).
- November 23, 1999: Petitioner’s TCTs on the 109.625 ha were cancelled; new TCTs (Nos. T-154155 to T-154160) issued in the Republic’s name.
- August 5, 2000: DAR identified 278 CARP beneficiaries; October 26, 2000: six Certificates of Land Ownership Award (CLOAs) issued in their favor.
- Lower Court Proceedings
- July 2, 2002: Petitioner sued respondents (Diamond Farm Workers MPC, individual workers, and 100 John Does) for unlawful occupation of 74.3393 ha, damages, and attorney’s fees.
- Respondents counterclaimed for recognition of their rights as CARP beneficiaries and for production/profit share, alleging petitioner’s refusal since 1995.
- Regional Adjudicator and DARAB denied petitioner’s complaints, granted respondents’ counterclaims; Court of Appeals affirmed with deletion of lease-rental awards. Petitioner then appealed to the Supreme Court.
Issues:
- Are respondents guilty of unlawful occupation and liable for damages and attorney’s fees?
- Should petitioner turn over possession of the subject land and respect respondents’ possession?
- Was the award of production share and interest proper under Section 32, CARL?
- Does petitioner’s challenge to non‐payment of just compensation constitute a collateral attack on the Republic’s titles, and is such issue properly before this Court?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)