Case Digest (G.R. No. 127876)
Case Digest (G.R. No. 127876)
Facts:
Roxas & Co., Inc. v. The Honorable Court of Appeals, et al., G.R. No. 127876, December 17, 1999, Supreme Court En Banc, Puno, J., writing for the Court. Petitioner Roxas & Co., Inc. is the registered owner of three haciendas in Nasugbu, Batangas: Hacienda Palico (1,024 ha, TCT No. 985), Hacienda Banilad (1,050 ha, TCT No. 924) and Hacienda Caylaway (867.4571 ha, four titles TCT Nos. T-44662–65). The central dispute concerns the Department of Agrarian Reform’s (DAR) acquisition of portions of those haciendas under Republic Act No. 6657 (the Comprehensive Agrarian Reform Law or CARL) and petitioner’s contemporaneous applications to have the lands converted to non‑agricultural use.During 1989 DAR field officers (MARO and PARO), assisted by the Barangay Agrarian Reform Committee and Land Bank of the Philippines (LBP), prepared investigation and summary investigation reports recommending compulsory acquisition of specified portions of Haciendas Palico and Banilad; DAR thereafter issued Notices of Acquisition (December 12, 1989) and later, after valuation steps and trust-account measures, the issuance and distribution of Certificates of Land Ownership Award (CLOA) to purported farmer‑beneficiaries (CLOAs registered from October 1993 and distributed October 30, 1993). For Palico and Banilad DAR opened or earmarked LBP trust accounts and later replaced these with cash and LBP bonds; petitioner contends no valid payment in cash or LBP bonds was properly received before transfer.
Hacienda Caylaway was the subject of a Voluntary Offer to Sell (VOS) filed May 6, 1988; DAR Regional Resolutions of January 12, 1989 accepted the VOS for two titles and DAR later issued Notices of Acquisition for portions of those titles (September 4, 1990). Petitioner sought withdrawal of the VOS (1992) and filed conversion applications (May 4, 1993; reiterated July 14, 1993), claiming 1975 Presidential Proclamation No. 1520 and subsequent local zoning reclassified the municipality as a tourist zone and rendered the lands non‑agricultural.
Procedurally, petitioner filed an administrative challenge (Case No. N‑0017‑96‑46 (BA)) with the DAR Adjudication Board (DARAB), which treated the issue as a prejudicial question and referred the determination whether the property was subject to agrarian reform to the Secretary of DAR. Petitioner then filed a petition with the Court of Appeals (CA‑G.R. SP No. 32484) seeking relief from the DAR proceedings; the Court of Appeals dismissed the petition on April 28, 1994, and denied reconsideration on January 17, 1997. Petitioner brought the present recourse to the Supreme Court seeking relief from the CA decision and challenging the validity of DAR’s acquisition process, the adequacy of notice and compensation, and asserting entitlement to conversion of the lands. The Supreme Court resolved the petition En Banc.
Issues:
- Was petitioner excused from exhausting administrative remedies before DAR and its tribunals such that the courts could take immediate cognizance of its claims?
- Were the DAR acquisition proceedings over the three haciendas valid and in accordance with RA 6657 and its implementing DAR administrative orders (i.e., did DAR observe the required identification, notice, hearing, and payment procedures)?
- May the Supreme Court decide petitioner’s pending applications for conversion of the haciendas from agricultural to non‑agricultural use, or does DAR have primary jurisdiction to resolve conversion applications?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)