Case Summary (G.R. No. 157171)
Key Dates
• June 10, 1988 – Enactment of R.A. No. 6657 (Comprehensive Agrarian Reform Law).
• January 2, 1989 – DAR issues Guidelines and Procedures for Production and Profit Sharing (Sections 13 & 32).
• January 9, 1989 – DAR issues Rules and Regulations for Section 11 (Commercial Farms).
• July 4, 1989 – Supreme Court denies preliminary injunction.
• August 24, 1989 – Supreme Court grants preliminary injunction upon posting of P100,000 bond.
• December 4, 1990 – Decision rendered by the Supreme Court, En Banc.
Applicable Law
• 1987 Philippine Constitution, Article XIII, Section 4 (Agrarian Reform Program).
• R.A. No. 6657, Sections 3(b), 11, 13, 16(d), 17, and 32.
• DAR Guidelines (Jan. 2, 1989) and DAR Rules (Jan. 9, 1989).
Factual Background
Luz Farms and similarly situated livestock and poultry raisers face compulsory coverage under R.A. 6657, which defines “agricultural activity” to include livestock and poultry, classifies commercial farms to cover such operations, and mandates production-sharing plans directing distribution of a percentage of gross sales and net profits to farmworkers pending land redistribution.
Constitutional Provision
Article XIII, Section 4 of the 1987 Constitution mandates a State-undertaken agrarian reform program founded on the right of landless farmers and regular farmworkers to ownership or a just share in the fruits of the land, subject to priorities and reasonable retention limits.
Issue
Whether Sections 3(b), 11, 13, and 32 of R.A. 6657, and corresponding DAR rules and guidelines, are unconstitutional insofar as they extend agrarian-reform coverage and production-sharing requirements to livestock, poultry, and swine raising.
Petitioner’s Arguments
• Livestock and poultry raising are industrial, not arable, activities; land constitutes a negligible portion of total investment and does not yield crops.
• Farmworkers in these enterprises differ from agricultural tenants: they receive fixed wages, social-security and minimum-wage protections, and no share tenancy is involved.
• Mandatory production-sharing (3% of gross sales; 10% of net profits) is confiscatory and violates due-process guarantees.
Respondent’s Arguments
• The ordinary meaning of “agriculture” includes livestock management and husbandry.
• Webster’s definition describes farming and livestock raising as components of agricultural practice, justifying inclusion under R.A. 6657.
Supreme Court’s Analysis (Majority)
Interpretation of Article XIII, Section 4 must begin with its text and framers’ intent. Transcripts of the 1986 Constitutional Commission reveal a deliberate limitation of “agricultural land” to arable uses (crop lands, fishponds, saltbeds), expressly excluding livestock and poultry operations. The Court held that inclusion of livestock and poultry raising under the agrarian-reform program transcends constitutional mandate, rendering Sections 3(b) and 11 and the production-sharing directives of Sections 13 and 32, together with their implementing rules and guideline
...continue readingCase Syllabus (G.R. No. 157171)
Facts
- Republic Act No. 6657, the Comprehensive Agrarian Reform Law of 1988, was approved on June 10, 1988, extending coverage to livestock, poultry, and swine raising.
- On January 2, 1989, the Secretary of Agrarian Reform promulgated Guidelines and Procedures Implementing Production and Profit Sharing under Sections 13 and 32 of R.A. 6657.
- On January 9, 1989, the Secretary issued Rules and Regulations implementing Section 11 of R.A. 6657 defining “commercial farms.”
- Luz Farms, a corporation engaged in livestock and poultry production, alleged that Sections 3(b), 11, 13, 16(d), 17, and 32 of R.A. 6657, plus the related Guidelines and Rules, would adversely affect it and similarly situated raisers.
- The petitioner sought: (a) declaratory relief that the challenged provisions are unconstitutional; and (b) preliminary and permanent injunctive relief against their enforcement as applied to livestock and poultry raisers.
Procedural History
- May 1989: Luz Farms filed a petition for prohibition with prayer for restraining order and/or injunction.
- July 4, 1989: The Court denied the motion for preliminary injunction.
- August 24, 1989: Upon bond posting of ₱100,000.00, the Court granted injunctive relief and gave due course to the petition.
- Parties filed memoranda: Luz Farms on September 6, 1989; Solicitor General adopted his comment as memorandum on December 22, 1989.
- December 4, 1990: The Supreme Court rendered judgment en banc.
Issues
- Whether Sections 3(b), 11, 13, and 32 of R.A. 6657, insofar as they include the raising of livestock, poultry, and swine within the agrarian reform program, violate the Constitution.
- Whether the production‐sharing requirement under Sections 13 and 32 is unreasonable or confiscatory, thus violating due process.
- Whether the Implementing Rules and Guidelines and Rules and Regulations that apply those sections to Luz Farms are valid.
Petitioner’s Contentions
- Livestock and poultry raising differs fundamentally from crop or tree farming; land is inc