Case Summary (G.R. No. 188299)
Applicable Law
The primary legislation involved in this case is Republic Act No. 6657, also known as the Comprehensive Agrarian Reform Law (CARL), effective from June 15, 1988, which governs the classification of lands for Agricultural Reform. The law defines agricultural lands and outlines the coverage of agrarian reform programs.
Background of the Case
The petitioners' land was subjected to compulsory acquisition under the CARP, with a Notice of Land Valuation and Acquisition issued on August 20, 1998. The Department of Agrarian Reform (DAR) identified several respondents as qualified farmer-beneficiaries, subsequently issuing Certificates of Land Ownership Award (CLOAs) in their favor. The petitioners, however, sought to cancel the CLOAs and declare the property exempt from CARP coverage based on a municipal ordinance reclassifying the land into a light intensity industrial zone before the enactment of CARL.
Ruling of the DARAB Calapan City
In a decision dated August 26, 1999, the DAR Adjudication Board (DARAB) ruled in favor of the petitioners, ordering the cancellation of the CLOAs and upholding the land classification as non-agricultural based on the municipal ordinance. The DARAB concluded that since the property was classified as non-agricultural prior to the CARL's effectivity, it should be excluded from CARP coverage.
Ruling of the DARAB Central Office
The DARAB's Central Office later reversed the local DARAB's decision, stating that the local board erred by solely depending on assertions of reclassification and neglected the need for proper administrative clearance from the DAR. The Central Office found that further administrative determination was required to verify whether the petitioners' land was indeed exempt from CARP.
Response to the DARAB Central Office's Ruling
Following the DARAB Central Office's findings, the petitioners applied for an exemption clearance from CARP, which was initially granted by then-DAR Secretary Roberto M. Pagdanganan. His order emphasized the urbanizing character of the property and the fact that it had been classified as non-agricultural per various certifications.
Respondents' Motion for Reconsideration
The respondents filed a motion for reconsideration against the grant of exemption. In a resolution dated June 15, 2004, former DAR OIC-Secretary Jose Mari B. Ponce upheld the motion, arguing that the reclassification did not apply to the entire area claimed by the petitioners and emphasized the idea that subsequent ordinances passed well after the CARL's enactment could not retroactively classify the property as non-agricultural.
Further Rulings by the DAR
Subsequent motions for reconsideration by the petitioners were denied. The DAR's OIC-Secretary Nasser C. Pangandaman ruled that the ongoing agricultural nature of the land was evidenced by its uses and surrounding conditions, thus affirming its inclusion under CARP.
Ruling of the Office of the President
In a decision dated December 15, 2006, the Office of the President reinstated the DAR's grant of exemption, indicating that the subject property’s classification as a light intensity industrial zone had been established before the CARL's implementation, and subsequent agrarian reform initiatives could not validly apply to that procurement.
Ruling of the Court of Appeals
On March 13, 2009, the Court of Appeals reversed the Off
...continue readingCase Syllabus (G.R. No. 188299)
Background of the Case
- This case revolves around a dispute concerning a parcel of land located in Barangay Guinobatan, Calapan City, Oriental Mindoro, covered by Transfer Certificate of Title No. J-7205 (T-54199), encompassing an area of 158.77 hectares.
- The land was subject to compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP), as evidenced by a Notice of Land Valuation and Acquisition dated August 20, 1998.
- The respondents were identified as qualified farmer-beneficiaries and were issued Certificates of Land Ownership Award (CLOAs) on October 12, 1998.
Petition for Cancellation and Administrative Decisions
- On October 21, 1998, the petitioners filed a petition before the Department of Agrarian Reform Adjudication Board (DARAB) seeking cancellation of the CLOAs, revocation of the Notice of Valuation and Acquisition, and affirmation of the classification of the property as non-agricultural due to prior reclassification into a light intensity industrial zone under Municipal Ordinance No. 21, series of 1981.
- The DARAB Calapan City issued a decision on August 26, 1999, ordering the cancellation of the CLOAs, affirming the classification of the land for residential and commercial uses, and declaring it outside the purview of RA No. 6657 (CARL).
Appeal to DARAB Central Office
- Respondents appealed to the DARAB Central Office, which held that the local office had erred by solely relying on the petitioners' assertion of reclassification and not considering the need for DAR Secretary's determination a