G.R. No. 189162 - Polo Plantation Agrarian Reform Multipurpose Cooperative vs. Inson

In 2003, a 394.9020‐hectare portion of land owned by Polo Coconut Plantation, Inc. was placed under the coverage of the Comprehensive Agrarian Reform Program (CARP) pursuant to Republic Act No. 6657.
The process commenced with the issuance of a Notice of Coverage to the landowner, followed by the submission of a Memorandum of Valuation from the Land Bank of the Philippines and a subsequent Notice of Land Valuation and Acquisition.
When the landowner failed to respond, the Department of Agrarian Reform (DAR) conducted summary administrative proceedings to determine just compensation and issued a Certificate of Deposit.

A Certificate of Land Ownership Award (CLOA No. 00114438) was issued on January 27, 2004, and subsequently registered on January 30, 2004 under Transfer Certificate of Title (TCT) No. T-802 in favor of agrarian reform beneficiaries represented by POPARMUCO.
The beneficiaries were identified by the DAR based on its administrative rules under the Comprehensive Agrarian Reform Law, which allowed for the inclusion of qualified recipients who were not necessarily tenants of the land.

Polo Coconut challenged the coverage of its land under CARP and the qualification of the identified beneficiaries by filing a Petition for Certiorari before the Court of Appeals.
The Court of Appeals ruled in favor of Polo Coconut, cancelling the CLOA/TCT, on the ground that the identified beneficiaries were not tenants and that the land was no longer agricultural.
The Supreme Court reversed the Court of Appeals’ decision in its September 3, 2008 Decision, holding that the proper administrative remedies had not been exhausted and that Section 22 of the law allowed for beneficiaries beyond just tenants.

On June 30, 2009, a separate group of 164 alleged regular farmworkers filed a Petition for Inclusion/Exclusion questioning the beneficiary list in TCT No. T-802/CLOA No. 00114438.
They argued that they had not been properly informed of the identification and screening process and that the identified Certificate of Land Ownership Award holders were “outsiders” with no legitimate connection to the Polo Coconut property.
Concurrently, these parties sought a Cease and Desist Order to prevent any relocation or subdivision of the estate pending the resolution of their petition.

Acting on the Petition for Inclusion/Exclusion, respondent Regional Director Rodolfo T. Inson of the DAR of Region VII issued a Cease and Desist Order on July 7, 2009, directing affected parties to refrain from occupying or taking further steps on the land.
On March 12, 2010, respondent Inson issued an Order disqualifying certain members of POPARMUCO as beneficiaries based on various grounds such as lack of connection with the land, post-Notice employment, and other evidentiary shortcomings.
Subsequent motions and filings ensued, including a Motion to Quash the Cease and Desist Order and a Motion for Issuance of a Writ of Execution seeking enforcement of the September 3, 2008 Decision.

POPARMUCO, as aggrieved Certificate of Land Ownership Award holders, filed a Petition for Contempt against respondent Inson.
They contended that by taking cognizance of the Petition for Inclusion/Exclusion and issuing the Cease and Desist Order as well as the March 12, 2010 disqualification Order, respondent acted in defiance of the Supreme Court’s final and executory September 3, 2008 Decision.
The petition asserted that such acts amounted to disobedience of or resistance to a lawful writ, process, or order of the Court, thereby warranting punishment for contempt.

Whether the respondent Regional Director’s action of taking cognizance of the Petition for Inclusion/Exclusion and issuing subsequent administrative orders amounted to a defiance of the Supreme Court’s final September 3, 2008 Decision.

Did the issuance of the Cease and Desist Order and the March 12, 2010 disqualification Order constitute an act of contempt by disregarding the immutable finality of the Court’s decision?

Whether the respondent’s actions, falling within his administrative authority to revalidate or reassess the list of agrarian reform beneficiaries, can be legally equated with disobedience to a court order.

Is a reevaluation of beneficiary qualification, even if allegedly erroneous, automatically tantamount to contempt if done within the purview of administrative jurisdiction?

Whether the actions of the respondent, despite possible abuse of discretion in the administrative process, fulfill the necessary criteria for a finding of contempt under established jurisprudence.