G.R. No. 161796 - Land Bank of the Philippines vs. Estate of J. Amado Araneta

Land Bank of the Philippines, Department of Agrarian Reform (DAR), and Ernesto B. Duran, et al. filed separate petitions for review against the September 19, 2003 Decision of the Court of Appeals (CA) in CA-G.R. SP No. 65822.
The CA set aside the February 7, 2001 Decision of the DAR Adjudication Board (DARAB), which upheld agrarian reform coverage of 1,266 hectares out of a 1,644.55-hectare property owned by the Estate of J. Amado Araneta.
The CA ruled that the property had ceased to be agricultural land due to reclassification under Presidential Proclamation No. 1283, as amended by Proclamation No. 1637, and thus was outside DAR’s jurisdiction.

The disputed land (Lot No. 23, Montalban Cadastre) originally registered under Alfonso Doronilla.
Proclamation 1283 (June 21, 1974) excluded portions of the Marikina Watershed in Antipolo, Rizal, for townsite purposes, subject to private rights.
Proclamation 1637 (April 18, 1977) amended 1283 by increasing the area and including parts of San Mateo and Montalban, also subject to private rights.
Office of the Solicitor General (OSG) was directed by LOI 625 to initiate condemnation proceedings for private lands within the townsite, including Lot 23.

PD 27 (Tenant’s Emancipation Decree), issued October 21, 1972, aimed to emancipate tenant-farmers in rice and corn lands, placing tenanted rice/corn lands under Operation Land Transfer (OLT).
Tenants of Doronilla’s land organized themselves into farmer cooperatives and applied for Certificates of Land Transfer (CLTs).
DAR processed 106 CLTs covering 73 hectares; 75 CLTs were distributed to tenants before issuance of Proclamation 1637 halted further land transfer processing.

On March 15, 1983, J. Amado Araneta acquired ownership of the property through court litigation and obtained Transfer Certificate of Title (TCT) No. N-70860.
Proclamation No. 131 (July 22, 1987) instituted the Comprehensive Agrarian Reform Program (CARP).
DAR resumed OLT process for the property after CARP began, issuing a Notice of Acquisition on December 12, 1989.
The Estate of Araneta protested the land surveys and requested conversion from agricultural to non-agricultural use.
Land Bank approved land transfer claim covering 1,266 hectares in 1992 and offered just compensation to Araneta.
About 1,200 Emancipation Patents (EPs) were generated by 1990 in favor of 912 farmer-beneficiaries.

The Araneta Estate filed for cancellation of coverage under PD 27 and exemption from CARL coverage in 1992.
Regional Agrarian Reform Adjudicator (RARAD) ruled against Araneta in 1994, upholding OLT coverage and validity of land titles issued to farmers.
DARAB, on appeal, affirmed RARAD decision in 2001.
CA reversed DARAB decision in 2003, ruling that the property was reclassified non-agricultural under Proclamation 1637 and outside DAR jurisdiction.

Petitioners-intervenors (Duran, et al.) claimed they were deprived of the right to appeal the CA decision due to the death of their counsel and alleged improper service.

Whether CA erred in applying Proclamation Nos. 1283 and 1637 retroactively to exclude the property from agrarian reform coverage.
Whether the property ceased to be agricultural land upon inclusion in the LS Townsite reservation and thus outside DAR’s jurisdiction.
Whether the CLTs and EPs awarded to farmer-beneficiaries, particularly those issued after Proclamation 1637, are valid.
Whether the farmer-beneficiaries under PD 27 acquired vested rights and ownership over the property despite Proclamation 1637.
Whether landowners’ private rights prevail over tenants’ rights upon land reclassification.
Whether the intervention petition by Duran, et al. should be allowed despite the delay and death of their counsel.