Title
Sta. Rosa Realty Development Corp. vs. Amante
Case
G.R. No. 112526
Decision Date
Mar 16, 2005
Dispute over 254.766 hectares in Canlubang Estate: SRRDC contested CARP coverage, claiming land as a municipal park/watershed. Courts ruled it agricultural, upheld DARAB’s jurisdiction, and affirmed farmer-beneficiaries’ rights under CARP.
land ownership dispute
dismissal of claims
comprehensive agrarian reform law
A

Case Summary (G.R. No. 112526)

Factual Background

The subject controversy concerns two parcels of the Canlubang Estate in Laguna covered by Transfer Certificates of Title Nos. 81949 and 84891 measuring 254.766 hectares and located in Barangay Casile. The titles were held by STA. ROSA REALTY DEVELOPMENT CORPORATION, a company majority-owned by C.J. Yulo & Sons, Inc. Private respondents claimed ancestral and continuous occupation of portions of the estate since circa 1910 and alleged repeated disturbances of their possession by SRRDC security personnel. The land was the subject of parallel judicial actions for injunction and ejectment and of administrative proceedings under the Comprehensive Agrarian Reform Program (CARP).

Injunction Case (Civil Case No. B-2333)

On December 6, 1985, Amante, et al. filed an action for injunction with damages in the Regional Trial Court of Laguna against Luis Yulo, SRRDC and security personnel, alleging forcible entry, cutting of trees, burning of huts and dispossession. The trial court issued a writ of preliminary injunction on August 17, 1987. After trial, the trial court on January 20, 1992 dismissed the complaint and ordered plaintiffs to vacate the parcels and enjoined them from entering the land. The Court of Appeals later dissolved the preliminary injunction on April 22, 1988 and on June 28, 1994 affirmed with modification the trial court decision by awarding nominal damages of P5,000.00 per plaintiff, finding that SRRDC had disturbed the possessory rights of Amante, et al.

Ejectment Proceedings

Between October 1986 and August 1987 SRRDC filed forcible entry and ejectment cases in the Municipal Trial Court of Cabuyao against occupants. The MTC ruled for SRRDC on May 24, 1991, ordering surrender of possession. On appeal the Regional Trial Court of Biñan dismissed the ejectment complaints on February 18, 1992 for lack of jurisdiction because the subject land was agricultural and the DAR had primary jurisdiction. The Court of Appeals on January 17, 1995 dismissed SRRDC’s petition for review, finding inadequate proof of prior physical possession by SRRDC and declined to sustain the RTC’s finding that the lands were agricultural and that the occupants were tenants.

Administrative Proceedings Before the DAR and DARAB

In August 1989 the Municipal Agrarian Reform Office issued Notices of Coverage under CARP to SRRDC for titles T-81949, T-84891 and T-92014. SRRDC filed protests and objections, contending nonagricultural classification, watershed status and that occupants were not qualified beneficiaries. The Land Bank forwarded compulsory acquisition claim folders to the DARAB, and Secretary of Agrarian Reform issued notices of acquisition on December 12, 1989. By administrative route the DAR referred valuation matters and threshold questions of coverage and conversion to the DARAB, and the DARAB scheduled hearings for administrative valuation and threshold issues. SRRDC sought to disqualify private respondents as beneficiaries and to raise watershed and zoning classifications. The DARAB granted hearing dates, allowed SRRDC to participate and repeatedly urged SRRDC to present evidence.

DARAB Findings

On December 19, 1991 the DARAB dismissed SRRDC’s protest and affirmed compulsory coverage of the SRRDC landholdings, ordered LBP to pay valuation and directed cancellation of TCT Nos. 84891 and 81949 and reissuance in the name of the Republic of the Philippines, followed by distribution and issuance of CLOAs to identified farmer-beneficiaries. The DARAB found on ocular inspection and documentary evidence that the lands were under possession and tillage of identified farmer-beneficiaries, that the area was developed as a community with agricultural activity, and that topography was largely flat to undulating with slopes of three to fifteen percent and productive plantations, hence not an exempt watershed or nonagricultural area.

Court of Appeals Decisions on the DARAB and Related Matters

The Court of Appeals in CA-G.R. SP No. 27234 affirmed the DARAB decision on November 5, 1993, without prejudice to SRRDC litigating just compensation in the Special Agrarian Court. In a separate appellate disposition, the CA affirmed with modification the injunction case judgment and awarded nominal damages but clarified that its ruling would not preempt agrarian cases.

Supreme Court Proceedings and Issues Presented

SRRDC filed a petition in G.R. No. 112526 seeking review of the CA decision affirming DARAB, and Amante, et al. filed in G.R. No. 118838 seeking relief from the CA affirmance in the injunction proceedings. The principal issues brought before the Supreme Court included whether the subject parcels were agricultural and subject to compulsory acquisition under R.A. No. 6657, whether municipal zoning or watershed classification exempted the land from CARP coverage, whether SRRDC had been denied due process in DARAB proceedings, whether the DARAB had jurisdiction to determine coverage, and collateral questions such as entitlement to damages and conversion of trust accounts opened by LBP pursuant to DAR instructions.

Legal Reasoning of the Supreme Court

The Court reviewed the administrative record, DARAB findings, and appellate rulings and applied the statutory framework of R.A. No. 6657, its implementing administrative orders, and controlling jurisprudence. The Court recognized that the power to determine CARP coverage and to identify beneficiaries lies principally with the Secretary of Agrarian Reform under Section 50 and implementing DAR rules, but also acknowledged the DARAB’s authority where it was properly invoked and where parties actively participated. The Court found that SRRDC itself had invoked DARAB’s jurisdiction to determine coverage and had been afforded repeated opportunities to present evidence but had failed to adduce proofs during DARAB hearings. The Court emphasized that a municipal zoning ordinance enacted in 1979, which classified Barangay Casile as municipal park, did not retroactively convert existing agricultural lands and therefore did not remove land from CARP coverage. The Court applied the definition of agricultural land in Section 3(c) of R.A. No. 6657 and DAR Administrative Order No. 13 regarding slopes and exemptions, noting that lands with slopes over eighteen percent that were already developed for agricultural use as of June 15, 1988 remained allocable to qualified occupants. The Court found that the DARAB’s factual findings of agricultural use, habitations, supporting infrastructure and suitability for crops were supported by certifications, topography maps and other exhibits in the record and that SRRDC’s contrary evidence was largely presented belatedly and was not tested in DARAB proceedings. The Court rejected SRRDC’s reliance on Natalia Realty and on Central Mindanao University as inapposite. It also declined to entertain SRRDC’s constitutional challenge to Section 22 of R.A. No. 6657 because SRRDC did not raise the question at the earliest administrative opportunity and because the constitutional issue was not the lis mota of the proceedings.

Disposition and

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