Case Digest (G.R. No. 224831)
Facts:
Orlando D. Garcia, Amado Q. Calalang, Fernando Q. Calalang, and Bonifacio Q. Calalang v. Santos Ventura Hocorma Foundation, Inc., G.R. No. 224831, September 15, 2021, Supreme Court Second Division, Hernando, J., writing for the Court.The dispute concerns a 25.5699-hectare parcel registered in the name of Santos Ventura Hocorma Foundation, Inc. (SVHFI) under TCT No. 549661-R in Brgy. Cacutud (formerly Mamatitang), Mabalacat, Pampanga, and several parcels described in CLOAs issued to petitioners as farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP). The petitioners claimed ownership through CLOA Nos. covering various lots; SVHFI sought exemption of the whole parcel from CARP coverage.
Chronology: In September 2002 the Municipal Agrarian Reform Office (MARO) served a Notice of Coverage on SVHFI identifying the property as subject to compulsory CARP acquisition. SVHFI protested (Nov. 14, 2002), alleging reclassification and other defects; documentation for the claim folder was submitted to Land Bank of the Philippines (LBP) in February 2004, LBP issued a valuation April 22, 2004 and certified in April 2005 that compensation had been deposited for 21.4240 hectares. CLOAs covering 6.4515 hectares were registered and distributed to farmer-beneficiaries in July 2005. Records also showed SVHFI sold the land to the Bases Conversion and Development Authority (BCDA) roughly two years after the Notice of Coverage.
Administrative proceedings and rulings: On January 16, 2006 the DAR OIC Regional Director denied SVHFI’s protest and ordered documentation and distribution for the remaining portions; a motion for reconsideration was denied in an Order dated September 5, 2006 and an Order of Finality issued November 20, 2006. In 2007 SVHFI filed a Sworn Application for Exemption Clearance (July 18, 2007) before the DAR Secretary; petitioners filed a protest with DAR-CLUPPI. On December 10, 2007 then DAR Secretary Roberto Pagdanganan granted SVHFI’s application, finding reclassification to non-agricultural purposes prior to June 15, 1988 (relying on HLURB/MPDO certifications, DENR and NIA certifications, photographs, and an ocular inspection). Motions for reconsideration (Jan. 31 and Feb. 21, 2008) and a subsequent manifestation were denied by the DAR Secretary (Orders of Aug. 29, 2008 and May 13, 2009).
Administrative review: Petitioners appealed to the Office of the President (OP); the OP denied their appeal in a Decision dated December 17, 2013, affirming the DAR Secretary. Judicial review: petitioners filed a petition for review under Rule 43 before the Cou...(Pro-only)
Issues:
- Is the subject property owned by Santos Ventura Hocorma Foundation, Inc. exempt from CARP coverage?
- If exempt, are petitioners entitled to ownership and possession of the subject property by virtue of the previousl...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)