Case Summary (G.R. No. 100091)
Overview of the Case
This Petition for Review on Certiorari seeks to nullify the proceedings and decision of the DARAB dated September 4, 1989, and the decision of the Court of Appeals dated August 20, 1990, which ordered the segregation of 400 hectares of CMU land and its inclusion in the Comprehensive Agrarian Reform Program (CARP) for distribution to beneficiaries. CMU contends that the DARAB lacked jurisdiction over this case.
Background of the Central Mindanao University
CMU is an agricultural educational institution established to address the public demand for agricultural training in Mindanao. Its land encompasses 3,080 hectares, set aside by Proclamation No. 476 issued by former President Carlos P. Garcia in 1958, to serve as its campus. Over the years, CMU has undergone various expansions, leading to significant increases in enrollment, necessitating responsible land use and growth.
The Development of Agrarian Programs
In the early 1980s, CMU initiated programs allowing faculty and employees to cultivate parts of its land, structured under agreements that explicitly stated no landlord-tenant relationships existed. Despite participants, including complainants like Alvin Obrique, receiving assistance and land for agricultural projects, the agreements emphasized that such use was temporary and for specific purposes aligned with CMU's educational objectives.
DARAB's Findings
DARAB found the private respondents were not tenants nor landless peasants and thus not eligible under CARP. The agency concluded that their claims to CMU land were unfounded, as evidence indicated the arrangements with CMU were contractual and not indicative of tenancy.
Key Questions Raised by CMU
CMU raised critical questions concerning DARAB's jurisdiction to address the tenants' status and the validity of the Court of Appeals' ruling that upheld DARAB's decision. Specifically, CMU contested whether the land designated for educational purposes could be subjected to CARP's coverage, given its status as an educational institution.
Analysis of Land Use Definition Under CARP
The court examined the definitions utilized by DARAB regarding land use and relevance to educational institutions. Section 10 of RA 6657 provides exemptions for lands directly required for school sites and agricultural experimentation. The court contended that CMU's land was essential for its operations and future expansion, which should exempt it from agrarian reform mandates.
Jurisdictional Concerns and DARAB's Authority
While acknowledging DARAB's jurisdiction over agrarian disputes, the court stated that this authority is limited to properties that fal
...continue readingCase Syllabus (G.R. No. 100091)
Case Overview
- This case involves a Petition for Review on Certiorari under Rule 65 of the Rules of Court.
- The petitioner, Central Mindanao University (CMU), seeks to nullify the proceedings and decision of the Department of Agrarian Reform Adjudication Board (DARAB) dated September 4, 1989, and the Court of Appeals’ decision dated August 20, 1990.
- The DARAB decision ordered the segregation of 400 hectares from CMU land for inclusion in the Comprehensive Agrarian Reform Program (CARP) for distribution to qualified beneficiaries, which CMU contests on grounds of lack of jurisdiction.
Parties Involved
- Petitioner: Central Mindanao University, represented by its President Dr. Leonardo A. Chua.
- Respondents: The Department of Agrarian Reform Adjudication Board, the Court of Appeals, and Alvin Obrique, representing the Bukidnon Free Farmers Agricultural Laborers Organization (BUFFALO).
Background of the Case
- CMU is an agricultural educational institution established in early 1910, evolving from a farm school to a full-fledged university with a focus on agriculture.
- The land occupied by CMU was reserved for the Mindanao Agricultural College via Proclamation No. 476 by President Carlos P. Garcia on January 16, 1958, encompassing a total area of 3,080 hectares.
- The university faced opposition during its cadastral hearing from various tribes claiming ownership of ancestral lands, resulting in a reduction of titled land from 3,401 hectares to 3,080