Case Digest (G.R. No. 149927)
Facts:
The case involves the petitioners, the Heirs of Ramon Arce, Sr. (Eulalio Arce, Lorenza Arce, Ramon Arce, Jr., Mauro Arce, and Esperanza Arce), who owned a 76.39-hectare parcel of land in Brgy. Macabud, Montalban, Rizal. This land, covered by Transfer Certificates of Title (TCT) Nos. T-442673, 442674, 442675, and 442676, was used for livestock raising, specifically for milk and dairy production, since the 1950s, even prior to the enactment of Republic Act No. 6657 or the Comprehensive Agrarian Reform Law (CARL) in 1988. The farming method was feedlot operation, meaning livestock, such as cattle and goats, were confined and fed rather than allowed to graze freely. In 1998, following a liver fluke infestation, the Philippine Carabao Center recommended that the older milking livestock be transferred to a feedlot facility in Novaliches, Quezon City, leaving younger cattle on the subject lands. Despite this, the petitioners continued to grow napier grass on the land to feed their liveCase Digest (G.R. No. 149927)
Facts:
- Ownership and Historical Use of the Subject Lands
- The petitioners, identified as the Heirs of Ramon Arce, Sr., were registered owners since the 1950s of a parcel of land located in Brgy. Macabud, Montalban, Rizal, covering approximately 76.3964 hectares under Transfer Certificates of Title Nos. T-442673 to T-442676.
- The subject lands were used as pasture lands for rearing livestock such as buffaloes, carabaos, and goats for milk production, which was then processed into products like Selecta Carabao’s Milk and Ice Cream—now known as Arce Dairy Ice Cream.
- The farming method employed was a “feedlot operation,” where animals are confined and fed on a cut-and-carry (or zero grazing) basis.
- Livestock Management and Evidence Submitted
- In 1998, the Philippine Carabao Center-Department of Agriculture (PCC-DA) recommended transferring the older, milking, and more susceptible livestock to a separate feedlot facility in Novaliches, Quezon City, due to liver fluke infestation risks, while the younger cattle remained on the subject lands.
- Despite the transfer, petitioners maintained the cultivation of napier grass on their lands to supply fodder for both the livestock on the subject lands and those transferred to the Novaliches facility.
- In response to a Notice of Coverage issued on August 6, 2008 by the Provincial Agrarian Reform Officer (PARO), petitioners, through a letter dated October 17, 2008, submitted extensive documentary evidence (including Certificates of Ownership of Large Cattle, livestock inventories, and photos of the livestock operation) to argue for the exclusion of the subject lands from CARP coverage.
- Administrative Proceedings Prior to the Supreme Court Review
- On December 2, 2008, the Municipal Agrarian Reform Officer (MARO) recommended granting the petition for exclusion based on findings that the lands were primarily used for livestock operations.
- An Evaluation Report and Recommendation from the Legal Division of the DAR Provincial Office (DARPO) on March 4, 2009 further supported that the lands were directly and exclusively utilized for livestock raising, even before the enactment of RA 6657 in 1988.
- On September 30, 2009, petitioners filed a Manifestation to Lift the Notice of Coverage, reaffirming that the subject lands were integral to their livestock business, referencing longstanding usage for pasture and feed production.
- Consequently, on December 22, 2009, DAR Regional Director Antonio G. Evangelista issued an Order granting the petition for lifting the Notice of Coverage, which later became final on April 29, 2011.
- Not long after, an Ocular Inspection Report by Ucag (DAR Region IV-A) dated May 12, 2011, asserted that no livestock or cattle were present on the subject lands—an observation that sharply contrasted with previous findings.
- Following this, SAMANACA (a farmers’ organization) submitted petitions aiming to annul the RD Evangelista’s Order, ultimately leading to conflicting administrative positions.
- On December 7, 2012, DAR Secretary Virgilio R. De Los Reyes issued an Order denying the petition for exclusion based on the alleged absence of livestock.
- Petitioners filed multiple motions for reconsideration and an Appeal Memorandum, arguing due process violations and presenting additional evidence of ongoing livestock presence and operations.
- The Office of the President (OP) then issued a Decision on April 29, 2015, reversing the DAR Secretary’s Order and granting the exclusion from CARP coverage for the subject lands.
- Subsequently, the DAR filed a Petition for Review with the Court of Appeals (CA), which issued a Decision on August 5, 2016, and a Resolution on November 28, 2016, effectively denying the petitioners’ exclusion claim by emphasizing that the lands were no longer exclusively maintained for livestock grazing.
- In response, petitioners filed the current petition for Review on Certiorari with the Supreme Court, challenging the CA’s reliance on flawed factual findings and the alleged administrative lapse in due process.
- Intervention Attempt by SAMANACA
- On March 20, 2018, SAMANACA filed an Ex-parte Motion for Leave to Intervene based on the assertion that its members were identified as qualified beneficiaries of the subject lands.
- The petitioners, however, contended that SAMANACA lacked legal standing, as its members were never in possession of, tenants on, or actively engaged in the cultivation or farming of the subject lands.
Issues:
- Exemption from CARP Coverage
- Whether the subject lands, which have been used exclusively for livestock raising (a practice dating back to the 1950s), are exempt from the coverage of Republic Act No. 6657 (the Comprehensive Agrarian Reform Law).
- Whether the transfer of selected livestock in 1998 for health reasons impacts the classification of the subject lands as being used for livestock raising.
- Factual Determinations and Due Process
- Whether the DAR’s reliance on an ocular inspection report (conducted by Ucag without prior notice) qualifies as a proper factual finding in light of the substantial evidence provided by petitioners.
- Whether the earlier administrative findings by the MARO and DARPO—supporting the exclusive use of the lands for livestock operations—should have been given greater weight.
- Standing to Intervene
- Whether SAMANACA has a direct and immediate legal interest sufficient to justify its intervention in the case, especially given that its members were not direct users, tenants, or cultivators of the subject lands.
- Exhaustion of Administrative Remedies
- Whether the CA and the DAR’s decisions improperly reversed well-established administrative and factual determinations despite the exhaustion of available administrative remedies by the petitioners.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)