Case Summary (G.R. No. 139173)
Antecedent Facts
The petitioners were registered owners of a 76.39-hectare parcel of land that was historically utilized for livestock raising. This land was dedicated to the feeding and dairy production of carabaos, cattle, and goats. Following recommendations from the Philippine Carabao Center, some livestock were relocated to a secondary facility in Quezon City to prevent a liver fluke infestation, while younger animals remained on the original land. Petitioner farmers continued to maintain napier grass, a vital source of fodder, on the subject lands.
Notice of Coverage and Petition for Exclusion
In August 2008, the Provincial Agrarian Reform Officer issued a Notice of Coverage (NOC) under the Comprehensive Agrarian Reform Program (CARP). In response, the petitioners submitted a Petition for Exclusion citing their long-term use of the land for livestock purposes, along with substantial evidence supporting their claims. Both local and regional agrarian reform officers subsequently recommended the granting of the petition based on the land's historical use as a livestock farm.
DAR Decision and Initial Favor
In December 2009, the Regional Director of the Department of Agrarian Reform issued an order granting the exclusion of the subject lands from CARP. This order was confirmed as final and executory as no appeals were filed. However, subsequent inspections reported a lack of livestock on the land, leading to controversy over the status of the subject properties.
Challenge and Subsequent Rulings
Facing opposition from local farmer organizations, the Department of Agrarian Reform Secretary, in December 2012, reversed the earlier decision and denied the exclusion petition. The denial was based on claims that the land was no longer being used for livestock activities, as evidenced by an ocular inspection report.
Arguments of Petitioners
In their appeal, the petitioners contended that the DAR's reversal was unfounded and that the inspections violated their rights to due process. They maintained that their lands were still utilized for livestock raising and emphasized the historical use dating back to before the enactment of CARP. Furthermore, they argued that the evidence relating to the absence of livestock was misleading, as some livestock had been relocated for health reasons without disqualifying the land's status.
Findings and This Court's Ruling
The Supreme Court found merit in the petitioners' arguments, determining that the subject lands should be exempt from CARP coverage based on historical use for livestock raising. The Court emphasized that the transfer of certain livestock did not negate the agricultural classification of the land.
Legal Framework and Constitutional Context
In analyzing the case's legal foundations, the Court referred to the 1987 Constitution and relevant actions under RA 6657, emphasizing the intent of the agrarian reform polici
...continue readingCase Syllabus (G.R. No. 139173)
Case Overview
- The case involves a petition for Review on Certiorari filed by the Heirs of Ramon Arce, Sr. against the Department of Agrarian Reform (DAR) concerning a decision and resolution issued by the Court of Appeals (CA) on August 5, 2016, and November 28, 2016, respectively.
- The core issue pertains to the exemption of the subject lands from the coverage of the Comprehensive Agrarian Reform Law (CARL) of 1988.
Antecedent Facts
- The Heirs of Ramon Arce, Sr. were registered owners of approximately 76.39 hectares of land in Brgy. Macabud, Montalban, Rizal, utilized primarily for livestock raising.
- The lands were used for feedlot operations, particularly for breeding buffaloes, carabaos, and goats, contributing to the production of milk and dairy products, specifically Arce Dairy Ice Cream.
- In 1998, a recommendation from the Philippine Carabao Center led to the transfer of older livestock to another facility due to health concerns, while younger animals remained on the subject lands.
Notice of Coverage and Petition for Exclusion
- On August 6, 2008, the Provincial Agrarian Reform Officer (PARO) issued a Notice of Coverage (NOC) under the CARP over the subject lands.
- The petitioners submitted a request for exclusion from CARP coverage on October 17, 2008, arguing that the lands had been used for livestock raising since before the CARP's enactment, providing substantial documentary evidence to support their claim.
Reports and Recommendations
- The Municipal Agrarian Reform Officer (MARO) and DAR Provincial Office (DARPO) both conducted evaluations and recommended granting the petition for exclusion from CARP coverage,