Title
Central Mindanao University vs. Department of Agrarian Reform Adjudication Board
Case
G.R. No. 100091
Decision Date
Oct 22, 1992
CMU's land, used for educational and agricultural research, exempt from CARP; no tenant-landlord relationship with complainants; DARAB lacked jurisdiction.
labor law
tenancy
landless peasants

Case Summary (G.R. No. 100091)

Factual Background

CMU is a state-owned agricultural educational institution whose reservation of 3,080 hectares was withdrawn from sale and reserved for the school by Proclamation No. 476 and subsequently surveyed, registered and titled to the university under OCT Nos. 160, 161 and 162. The university historically used the land for campus, experimental stations, watershed, and multiple agricultural projects. From small beginnings the student population expanded markedly, producing concurrent demands for expanded facilities and agricultural research land. In the 1980s the university implemented self-help agricultural programs including the Kilusang Sariling Sikap Program and the CMU-Income Enhancement Program. These programs granted groups of faculty, staff and later some former workers the use of limited parcels for one-year projects under written agreements that expressly disclaimed a landlord-tenant relationship and imposed restrictions on residence and use of the allotted lots.

Events Leading to the Complaint

The discontinuance of CMU’s larger agri-business project and the resulting termination or separation of some personnel, including Alvin Obrique, precipitated grievances. Obrique and others who had participated in the CMU projects filed a complaint with the Department of Agrarian Reform Adjudication Board, docketed as DAR Case No. 5, claiming tenancy status and asserting they were landless peasants occupying portions of CMU lands amounting to about 1,200 hectares. The complainants styled themselves as the Bukidnon Free Farmers and Agricultural Laborers Organization (BUFFALO).

DARAB Findings and Order

The DARAB determined that the private respondents were not tenants and could not qualify as beneficiaries under the CARP. Nevertheless, the Board ordered the segregation of 400 hectares of suitable, compact and contiguous portions of the CMU land and directed inclusion of that area in the CARP for distribution to qualified beneficiaries. The Board’s segregation order rested principally on its view that the questioned area was not “directly, actually and exclusively used” for school purposes because portions had been committed under arrangements with private entities such as Philippine Packing Corporation (now Del Monte Philippines).

Proceedings in the Court of Appeals

The Court of Appeals affirmed the DARAB decision in a judgment dated August 20, 1990. The appellate tribunal accepted DARAB’s construction that the lands in question were not presently and exclusively used for educational purposes and thus fell within the coverage of R.A. 6657.

Issues Presented to the Supreme Court

The petitioner raised two principal issues: (1) whether the DARAB had jurisdiction to hear and decide DAR Case No. 5 for declaration of tenancy status and coverage under the CARP, and (2) whether the Court of Appeals committed serious errors and grave abuse of discretion amounting to lack of jurisdiction in affirming the DARAB decision.

Court’s Findings on the Status of the Complainants

The Supreme Court agreed with the DARAB’s separate finding that the private respondents were not tenants. The written agreements under the CMU livelihood programs expressly denied any landlord-tenant relationship. The CMU did not share in harvests as a landlord would but received only nominal service and participant fees. The Court further observed that the complainants’ allegation of being “landless peasants” required proof. The record did not establish that the complainants were landless peasants as that term was asserted. The Court concluded that the complainants entered CMU land by permission for limited educational and experimental purposes and that any continued occupation after expiration of those privileges was unauthorized; accordingly, some complainants were properly characterized as squatters whose presence did not qualify them for CARP benefits under Sec. 73, R.A. 6657.

Legal Framework Governing Coverage and Exemptions

The Court reviewed Sec. 4 and Sec. 10 of R.A. 6657. Section 4 defines lands covered by the CARP. Section 10 exempts from coverage lands “actually, directly and exclusively used and found to be necessary” for specified public and institutional purposes, including school sites and campuses and experimental farm stations operated by public or private schools for educational purposes. The Court also noted the DAR’s quasi-judicial adjudicatory powers under Executive Order No. 129-A, Secs. 13 and 17, and Sec. 50 of R.A. 6657, but emphasized that those powers are limited to matters within the CARP’s coverage.

Court’s Analysis of the DARAB’s Segregation Order

The Court held that the DARAB and the Court of Appeals misconstrued Section 10 by applying a narrow temporal test that confined exempt use to present, active exploitation to the exclusion of future institutional needs. The Court found that CMU’s reservation was intended as a land-grant style campus with capacity for future expansion and that CMU’s land-use plans, historical development, and educational purposes justified reserving substantial tracts for educational and experimental uses. The Court further explained that agreements with private entities, including the pre-CARP management and development arrangements with Philippine Packing Corporation and like undertakings, were entered into in connection with the university’s research and educational objectives and were executed prior to the enactment of R.A. 6657. The Court held that the determination of what lands are necessary for the school’s educational purposes is primarily for the school to make, subject to judicial review only where evidentiary facts show manifest lack of need.

Limitation on Quasi-Judicial Power and Excess of Authority

Although the DARAB has primary jurisdiction over agrarian disputes, the Court emphasized that such quasi-judicial authority does not permit a tribunal to grant relief beyond that demanded by the parties or to order disposition of private titled lands outside the CARP’s coverage when complainants are found not to be entitled to agrari

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