G.R. No. 196028 - Samahan ng Magsasaka at Mangingisda ng Sitio Naswe, Inc. vs. Tan

Samahan ng Magsasaka at Mangingisda ng Sitio Naswe, Inc. (SAMMANA), an association of farmers and fishermen based in Sitio Talaga, Barangay Ipag, Mariveles, Bataan.
Represented by its president, Rogelio A. Commendador, the association alleges that its members reside and earn their living by farming on the disputed land.

Tomas Tan, who emerged as the highest bidder in a sale of a portion of a government-sequestered land, and
Beneficiary of the transaction resulting from the privatization process executed by the Presidential Commission on Good Governance (PCGG).

The subject property is part of a 129.4227-hectare tract in Barangay Ipag, Mariveles, Bataan, initially owned by Anchor Estate Corporation.
The PCGG sequestered the land after it was identified as being owned by a dummy corporation linked to the late President Ferdinand E. Marcos.

On April 4, 1995, the PCGG published an Invitation to Bid for the sale of its assets, including 34 hectares of the disputed land.
Tomas Tan became the highest bidder, and subsequent approvals were granted by the PCGG Committee on Privatization, the Office of the President (OP), and other administrative offices.
A Deed of Sale was executed on August 1, 2000, formalizing the transfer of the 34-hectare parcel to the respondent.

Prior to the sale, on June 16, 1994, a Notice of Coverage under the Comprehensive Agrarian Reform Program (CARP) had been issued for the entire 129.4227-hectare land.
On July 25, 2000, the then Chairman of the PCGG Committee on Privatization, Jorge V. Sarmiento, requested the Department of Agrarian Reform (DAR) to halt CARP acquisition proceedings over the land.
The DAR Secretary, Horacio R. Morales, Jr., responded via an Order on July 26, 2000, lifting the Notice of Coverage and stopping the acquisition proceedings.

On October 29, 2004, SAMMANA filed a petition with the DAR to revoke the July 26, 2000 Order, challenging the lifting of the Notice of Coverage.
The DAR denied the petition and its motion for reconsideration in subsequent orders (February 3, 2006, and September 26, 2006).
The petitioner then sought recourse by appealing to the OP, but its appeal was dismissed on April 10, 2007.

SAMMANA filed a Petition for Review under Rule 43 with the Court of Appeals (CA).
In a decision dated July 27, 2010, the CA dismissed the petition on the ground that the petitioner was not a real party in interest, emphasizing that its members were not qualified or registered CARP beneficiaries.
The petitioner’s subsequent motion for reconsideration before the CA was also denied before they filed the present petition for review on certiorari.

Although SAMMANA claimed a representative role for its members (farmers and fishermen), it failed to demonstrate that its members were identified, registered, or recognized as qualified beneficiaries under CARP.
The petitioner admitted that due to the July 26, 2000 DAR Order, its members’ case folders were not processed, thereby reducing their claim to an unenforceable expectancy rather than an actual right.

The DAR Order lifting the Notice of Coverage had attained finality, especially since no appeal or motion for reconsideration was adequately maintained within the prescribed period.

Whether SAMMANA, as an association of farmers and fishermen, qualifies as a real party in interest to challenge the DAR Secretary’s Order lifting the Notice of Coverage.
Whether mere representation of members, without proving that they are designated and qualified CARP beneficiaries, satisfies the real interest requirement.

Whether the procedural steps taken by the DAR—specifically lifting the Notice of Coverage one day after the request by the PCGG Chairman—were irregular or erroneous under existing administrative rules.
Whether the underlying administrative action was subject to judicial review given its finality.

Whether the finality of the DAR Order, as prescribed under E.O. No. 292 and allied administrative rules, precludes judicial review of the decision despite potential irregularities in procedure.