Facts:

The case in question, Noel L. Ong, Omar Anthony L. Ong, and Norman L. Ong vs. Nicolasa O. Imperial, et al., G.R. No. 197127, is a petition for review on certiorari that was decided by the Supreme Court of the Philippines on July 15, 2015. The petitioners, Noel, Omar Anthony, and Norman Ong, are the registered owners of a 405,645 square meter parcel of land (Transfer Certificate of Title No. T-17045) located in Barangay Dogongan, Daet, Camarines Norte. In 1994, the Municipal Agrarian Reform Officer (MARO) issued a Notice of Coverage under the Comprehensive Agrarian Reform Law (CARL), which the petitioners contested in a letter dated April 26, 1995, citing reasons for objection including previous use of the land for grazing prior to the CARP's enactment and citing pending legislative bills that might alter retention limits. The MARO responded on May 31, 1995, asserting that the land was used for coconut production, thus under CARP coverage as the retention area was exceeded.

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Facts:

Ownership and Subject Property

• Petitioners Noel L. Ong, Omar Anthony L. Ong, and Norman L. Ong are registered owners of a parcel of land covering 405,645 square meters under TCT No. T-17045, located in Barangay Dogongan, Daet, Camarines Norte.
• The property was originally agricultural in nature, used for coconut production despite an initial protest alleging its use for livestock grazing.

Initiation of Agrarian Reform Coverage

• On August 14, 1994, the Municipal Agrarian Reform Officer (MARO) of Daet issued a Notice of Coverage packaging the land under the Comprehensive Agrarian Reform Law (CARL).
• Petitioners, by means of a protest letter dated April 26, 1995, contended that:
• The area had long been used as grazing land (and should be excluded from coverage).
• After deducting the landowner’s retention area, the excess area was minimal.
• Pending congressional bills might render the retention area calculation moot, possibly leading to confusion.

MARO’s Response and Subsequent Notice of Acquisition

• On May 31, 1995, MARO Jinny Glorioso replied, clarifying that:
• The petitioners had confirmed the area’s use for coconut production.
• The land fell under CARL coverage because it exceeded the retention threshold (excess area computed as 8.5214 hectares).
• On September 23, 1996, a Notice of Acquisition was issued over the subject property.

Petitioners’ Application for Exemption

• On October 16, 1996, petitioners filed an application for exemption clearance with the DAR Regional Office V.
• They submitted supporting documents which included:
• Certified true copy of TCT No. T-17045.
• Location and vicinity maps.
• Certifications by the Deputized Zoning Administrator (DZA) and the HLURB verifying that the property was within a reclassified residential built-up area.
• Certification from the National Irrigation Administration (NIA) confirming the absence of irrigation projects covering the land.
• Documentation of tenant occupancy and a Deed of Undertaking concerning disturbance compensation.

Conflicting Verification and Agency Findings

• The DAR Regional Center for Land Use Policy, Planning and Implementation (RCLUPPI) V conducted an inspection and:
• Found that the land was predominantly agricultural, planted with coconuts.
• Noted that tenant occupations and prior reclassification as residential created conflicting claims.
• Subsequent evaluation by DAR Region V Director Percival C. Dalugdug, as well as orders issued by DAR Secretaries (February 2, 2000, and June 20, 2002), denied the exemption clearance on the ground that the property was under compulsory acquisition and the exemption application was untimely or deficient.

Administrative and Appellate Proceedings

• The Office of the President, in its decision dated September 5, 2005, reversed DAR’s denial and approved the petitioners’ application for exemption from CARP coverage, holding that:
• The property had been reclassified as residential prior to June 15, 1988, and thus it was no longer subject to CARL (which covers agricultural lands).
• The Notice of Acquisition issued by the MARO was void ab initio, as it pertained only to agricultural lands.
• A subsequent Order dated March 3, 2006 affirmed this decision.
• The Court of Appeals, in its November 30, 2010 Decision, reversed the Office of the President’s ruling, finding reversible error in exempting the property.
• Petitioners then elevated the matter through a petition for review challenging the CA’s ruling on both substantive reclassification issues and procedural intervention matters.

Divergent Expert Opinions and Documentary Inconsistencies

• The dispute centered on whether:
• The property’s reclassification as residential was valid on the basis of the pre-CARL Approved Town Plan (1978) and the later Zoning Ordinance (1980).
• The certifications issued by the HLURB versus those by the Deputized Zoning Administrator were consistent and sufficient in meeting the exemption requirements under DAR Administrative Order No. 6, Series of 1994.
• Petitioners argued that the local government’s authority to reclassify lands did not require subsequent HLURB approval for the 1980 ordinance.
• Respondents maintained that the inconsistency in certifications and the failure to establish a properly approved reclassification rendered the exemption improper.

Issue:

Exemption from CARP Coverage

• Whether the subject property, having been reclassified as residential prior to June 15, 1988, is exempt from the coverage of the Comprehensive Agrarian Reform Program.
• Whether the reclassification by the local government, based on the pre-CARL Town Plan and subsequent zoning ordinance, suffices to remove the property from the ambit of CARL despite discrepancies in documentary certifications.

Appellate and Intervention Procedures

• Whether the allowance of respondents’ motion to intervene—allegedly filed beyond the prescribed period—was proper under the Rules of Court, and whether the Court of Appeals properly reviewed errors not assigned on appeal.

Review of Documentary Evidence

• Whether the discrepancies between the HLURB certification and the Deputized Zoning Administrator’s certification should preclude the exemption clearance, particularly regarding the timing and approval of the zoning ordinance.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)