Case Summary (G.R. No. 192999)
Procedural History
Petitioner filed for unlawful occupation (July 2002), claiming continuing lawful possession pending final appeal of distribution order. Respondents counterclaimed for production and profit shares. The Regional Adjudicator and DARAB ruled against petitioner, ordered turnover of land, and awarded respondents P27.55 million production share plus interest. The CA affirmed, deleting lease‐rental award. Petitioner appealed to the Supreme Court.
Issues
- Are respondents guilty of unlawful occupation and liable for damages and attorney’s fees?
- Should petitioner turn over possession of the 109.625 ha and respect respondents’ possession?
- Was the award of production share and interest proper?
- Does the issue of just compensation bear on respondents’ status as lawful possessors?
Liability for Unlawful Occupation and Damages
Respondents are agrarian reform beneficiaries with CLOAs; their occupancy is lawful under CARP. Their act of guarding the land to prevent petitioner’s installation of other workers was a lawful exercise of the right to exclude intruders (Art. 429, Civil Code). Farm operations resumed by mutual agreement within days, negating any continuing unlawful occupation. Damages and attorney’s fees lack merit.
Turnover of Possession and Installation of Beneficiaries
Upon DAR’s deposit of compensation (cash or LBP bonds) and title issuance in the Republic’s name (Sec. 16(e)), petitioner lost ownership and possession of the 109.625 ha. CLOAs conferred ownership on beneficiaries (Sec. 24). Petitioner’s temporary management as farm operator does not override CARP’s mandate. The land must be turned over and beneficiaries installed promptly; DAR and PARO to assist DARAB in effecting distribution and installation (DAR AO 9, Rule XX).
Rights to Production‐Sharing and PPS Computation
Section 32 mandates a 3% share of gross annual sales to farm workers. Petitioner’s own data (11,000 boxes weekly, P1.46 million sales) and its P2.51 million deposit confirm gross‐sales basis. Net‐loss assertions do not affect the PPS computation. The DARAB’s award, based on the approved PPS Scheme, and the CA’s affirmation are upheld.
Just Compensation and Collateral Attack
Petitioner’s challenge rests on alleged nonreceipt of just compensation. Under CARL Secs. 56–57 and Sec. 17, just compensation is determined exclusively by the RTC acting as Special Agrarian Court, applying statutory factors. No SAC petition was filed here. The issuance of Republic titles and DAR deposit certifications imply payment or deposit of initial valuation; petitioner never assailed those titles. The CA correctly treated compensation as not at issue.
Distribution o
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Facts
- Diamond Farms, Inc. (petitioner) is a commercial banana-farming corporation owning 1,023.8574 hectares in Carmen, Davao.
- A 958.8574-hectare portion was initially deferred under CARP; deferment lifted on February 14, 1995, placing it under agrarian reform.
- 698.8897 hectares were awarded to a cooperative; petitioner retained management over 277.44 hectares, including a 109.625-hectare parcel.
- On November 23, 1999, petitioner's titles over the 109-hectare parcel were cancelled; the Republic received new TCTs.
- On August 5, 2000, DAR identified 278 beneficiaries (mostly respondents) for the 109-hectare land; CLOAs issued October 26, 2000.
- Petitioner cultivated 74.3393 hectares of the 109-hectare land, producing about 11,000 boxes of bananas weekly (₱1.46 million).
Procedural History
- July 2, 2002: Petitioner filed complaint for unlawful occupation, damages, attorney’s fees; sought vacation, harvesting rights, lost income, exemplary damages, fees, costs.
- Respondents admitted production figures, asserted cooperative rights, counterclaimed for production/profit share and interest.
- Regional Adjudicator (DAR-OAR) denied petitioner's reliefs, granted respondents’ counterclaims—holding petitioner no longer owner, respondents lawful occupiers.
- DARAB denied petitioner’s appeal, modified award (₱27.55 million less deposit, plus lease rentals and interest), encouraged agribusiness venture.
- CA affirmed DARAB decision but deleted lease rentals and interest awards.
- Petitioner’s motion for partial reconsideration denied; petition for review filed.
Issues for Resolution
- Whether respondents are guilty of unlawful occupation and liable for damages and attorney’s fees.
- Whether petitioner must turn over possession of the 109-hectare land and respect respondents’ possession.
- Whether the DARAB’s award of production share and interest is proper.
- Whether petitioner’s claim of nonpayment of just compensation affects respondents’ possessory rights and entitlements.
Unlawful Occupation
- Respondents identified as agrarian reform beneficiaries; CLOAs i