Case Digest (G.R. No. 103302)
Facts:
Natalia Realty, Inc. and Estate Developers and Investors Corp. (collectively referred to as petitioners) are involved in a legal dispute with the Department of Agrarian Reform (DAR), then headed by Secretary Benjamin T. Leong and Director Wilfredo Leano, in connection with the classification of land they own. The case arises from a Notice of Coverage issued by DAR on November 22, 1990, regarding three parcels of land totaling approximately 125 hectares in Banaba, Antipolo, Rizal. These lands had previously been designated for residential use as part of the Lungsod Silangan Townsite through Presidential Proclamation No. 1637 on April 18, 1979. Petitioners had obtained the necessary permits for the development of these properties into a low-cost housing subdivision known as Antipolo Hills Subdivision, with phases of development spanning from 1982 to 1986.When Republic Act No. 6657, known as the Comprehensive Agrarian Reform Law (CARL), took effect on June 15, 1988, DAR included
Case Digest (G.R. No. 103302)
Facts:
Petitioner Natalia Realty, Inc. (NATALIA) owned three contiguous parcels of land in Banaba, Antipolo, Rizal, totaling approximately 125,0078 hectares, covered by Transfer Certificate of Title No. 31527. On April 18, 1979, Presidential Proclamation No. 1637 set aside over 20,000 hectares in the municipalities of Antipolo, San Mateo, and Montalban as townsite areas (the Lungsod Silangan Reservation) to address Metro Manila’s population overspill. This proclamation effectively converted the agricultural lands into areas for residential use. Petitioners, together with Estate Developers and Investors Corporation (EDIC), developed these lands into what became known as the Antipolo Hills Subdivision by securing preliminary approvals, locational clearances, and subsequent development permits for Phases I (1982), II (1983), and III (1986), in accordance with the requirements of P.D. 957 (the Subdivision and Condominium Buyers’ Protective Decree).After the Comprehensive Agrarian Reform Law (CARL or R.A. 6657) took effect on June 15, 1988, the Department of Agrarian Reform (DAR) issued, on November 22, 1990, a Notice of Coverage on the undeveloped portion (roughly 90,3307 hectares) of the subdivision, placing it under CARL. Petitioners immediately objected to this Notice by registering protests and seeking its cancellation through letters addressed to DAR officials. Meanwhile, a separate complaint filed by members of the Samahan ng Magsasaka sa Bundok Antipolo, Inc. (SAMBA) resulted in a temporary restraining order that hindered further development. Despite filing administrative protests and letters, no corrective action was taken by DAR, leading petitioners to elevate the matter to the courts.
Issues:
- Whether the undeveloped portions of the Antipolo Hills Subdivision, though originally agricultural, ceased to be so following their inclusion in the Lungsod Silangan Reservation for residential use prior to the effectivity of CARL.
- Whether the Notice of Coverage issued by DAR on November 22, 1990, which assumed jurisdiction of these lands under CARL, is valid when the lands had already undergone conversion to non-agricultural residential use.
- Whether petitioners, having complied with all applicable requirements under P.D. 957 and securing necessary permits, were obliged to exhaust administrative remedies before resorting to judicial intervention against the Notice of Coverage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)