Title
Luz Farms vs. Secretary, Department of Agrarian Reform
Case
G.R. No. 86889
Decision Date
Dec 4, 1990
Luz Farms challenged CARL provisions including livestock/poultry in agrarian reform; SC ruled them unconstitutional, citing undue burden and lack of constitutional basis.

Case Digest (G.R. No. 111080)
Expanded Legal Reasoning Model

Facts:

  • Enactment and Implementation of R.A. No. 6657
    • On June 10, 1988, R.A. No. 6657 (Comprehensive Agrarian Reform Law of 1988) was approved, extending agrarian reform coverage to “raising of livestock, poultry and swine” (Sec. 3[b]).
    • On January 2, 1989, the Secretary of Agrarian Reform issued Guidelines and Procedures for Production and Profit Sharing (Secs. 13 & 32). On January 9, 1989, Rules and Regulations implementing commercial farms (Sec. 11) were promulgated.
  • Petition and Preliminary Injunction Proceedings
    • Luz Farms, a corporation engaged in livestock/poultry raising, filed a petition for prohibition with prayer for injunction, challenging Sections 3(b), 11, 13, 16(d), 17, and 32 of R.A. 6657 and related rules/guidelines as unconstitutional insofar as they apply to its operations.
    • The Supreme Court initially denied preliminary injunctive relief (Resolution dated July 4, 1989), then granted it upon posting of bond (Resolution dated August 24, 1989), and invited memoranda.

Issues:

  • Inclusion of Livestock and Poultry in Agrarian Reform Coverage
    • Whether the definition of “agricultural activity” under Section 3(b) (including livestock/poultry) exceeds the constitutional mandate for agrarian reform.
  • Validity of Commercial-Farm and Production-Sharing Provisions
    • Whether Section 11’s definition of commercial farms and Sections 13 & 32’s production-sharing requirements are unconstitutional as applied to livestock and poultry raisers.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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