Case Summary (G.R. No. 103302)
Applicable Law
The applicable law in this decision is the Comprehensive Agrarian Reform Law (R.A. 6657), the implementing rules surrounding agricultural land classification, and pertinent regulations concerning land development and residential purposes.
Factual Background
Petitioner Natalia Realty owns three contiguous parcels totaling approximately 125 hectares located in a townsite area proclaimed under Presidential Proclamation No. 1637 on April 18, 1979, aimed at developing housing for the population of Metro Manila. EDIC, as the developer, obtained various approvals and permits from governmental bodies, including the Human Settlements Regulatory Commission, authorizing the development of the Antipolo Hills Subdivision. This process included securing preliminary approvals and obtaining development permits, which were completed by the mid-1980s.
Notice of Coverage
On November 22, 1990, the DAR issued a Notice of Coverage encompassing undeveloped portions of the Antipolo Hills Subdivision, asserting that these lands fell under the CARL's coverage. Following this notice, both Natalia Realty and EDIC filed multiple objections and requests for cancellation of the DAR’s coverage, citing that their properties had ceased to be agricultural lands due to their designation for residential development.
Administrative Remedy Exhaustion
The respondents contended that the petitioners failed to exhaust administrative remedies, arguing that the complaint against them by members of the Samahan ng Magsasaka sa Bundok Antipolo, Inc. (SAMBA) was still pending at the DAR Regional Adjudicator. The argument was made that this situation warranted a halt in further legal action by the petitioners until the ongoing proceedings concluded.
Compliance with Legal Requirements
The petitioners rebutted the DAR's assertions, claiming compliance with all necessary legal requirements for the development of their properties into a residential subdivision. They highlighted that the permits they obtained specifically noted conformity with applicable regulations, reinforcing their argument that no further clearance from DAR was necessary for lands already designated for urban development.
Classification of Lands
The core legal inquiry pertains to whether the undeveloped portions of the Antipolo Hills Subdivision can still be classified as agricultural lands under R.A. 6657. The law explicitly defines agricultural lands as those not classified for residential, commercial, or industrial use. Since the properties were initially set aside for townsite development well before the CARL's enactment, the argument persists that these lands cannot be subsumed under the CARL’s jurisdiction.
Conclusion on Land Classification
The Supreme Court held that the undeveloped portions of the Antipolo Hills Subdivision were not classifiable as agricultural lands, given their history of designation for residential us
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Case Overview
- The case revolves around the interpretation of the Comprehensive Agrarian Reform Law of 1988 (R.A. 6657) concerning lands classified for residential, commercial, or industrial use prior to June 15, 1988.
- The central issue is whether the lands owned by petitioners, designated as townsite areas, fall under the coverage of R.A. 6657.
Parties Involved
- Petitioners:
- Natalia Realty, Inc. (NATALIA), owner of three contiguous parcels of land in Antipolo, Rizal.
- Estate Developers and Investors Corporation (EDIC), the developer of the NATALIA properties.
- Respondents:
- Department of Agrarian Reform (DAR), including Secretary Benjamin T. Leong and Director Wilfredo Leano of DAR-Region IV.
Background Facts
- NATALIA owns land parcels totaling 125.0078 hectares in Banaba, Antipolo, Rizal, covered by Transfer Certificate of Title No. 31527.
- Presidential Proclamation No. 1637, issued on April 18, 1979, set aside 20.312 hectares as townsite areas to accommodate population overspill in Metro Manila, designating the area as Lungsod Silangan Townsite.
- The properties were developed into Antipolo Hills Subdivision, with permits granted for three phases of development from 1982 to 1986.
Legal Proceedings
- On November 22, 1990, DAR issued a Notice of Covera