Case Summary (G.R. No. 112526)
Procedural History — administrative and judicial filings up to DARAB decision
Private occupants filed civil suits (easement, forcible entry) against SRRDC in 1985–1987; SRRDC counterclaimed for ejectment. Respondents petitioned DAR for compulsory acquisition. MARO issued a notice of coverage (Aug. 11, 1989) and convened a conference (Aug. 18, 1989). SRRDC filed objections (Aug. 17, 1989). PARO endorsed compulsory acquisition (Sept. 21, 1989). DAR Central/BLAD forwarded claim folders to LBP (Nov. 23, 1989). Secretary Santiago issued notices of acquisition (Dec. 12, 1989) with offered valuations. SRRDC protested the notices and valuation (Feb. 1990). Secretary Abad referred valuation and just-compensation determination to DARAB (Mar. 17, 1990). DARAB conducted proceedings and promulgated a decision ordering dismissal of SRRDC’s protest and compulsory acquisition with valuation and transfer instructions (decision dated Dec. 19, 1991). The Regional Trial Court (RTC) later found private respondents in bad faith in the ejectment action (Jan. 20, 1992). SRRDC appealed DARAB’s decision to the Court of Appeals, which affirmed (Nov. 5, 1993). The Supreme Court issued a temporary restraining order (Dec. 15, 1993) and ultimately set aside the Court of Appeals decision and remanded the matter to DARAB for re-evaluation (Supreme Court decision).
Applicable law and constitutional basis
Primary statutory framework: Republic Act No. 6657 (Comprehensive Agrarian Reform Law), particularly Section 16 (procedure for compulsory acquisition) and Section 10 (exemptions/exclusions, including lands used for watersheds and lands with slopes of 18% and over). Implementing administrative rules: DAR Administrative Order No. 12, series of 1989 (identification and compulsory acquisition case-folder procedures) and related AO provisions governing valuation and notice procedures. Constitutional basis: under the 1987 Philippine Constitution (applicable to this 2001 decision), CARP’s implementation involves an exercise of the State’s police power (regulatory limits on property) and the power of eminent domain (taking of title/possession with just compensation).
Central issues presented
- Whether the subject parcels were properly covered by compulsory acquisition under CARP despite assertions that they form part of a protected watershed area. 2. Whether the parcels were exempt from CARP coverage because they have slopes of 18% and over (Section 10 exemption). 3. Whether procedural requirements for acquisition—particularly notice, identification, and payment/deposit mechanisms under Section 16 and related AOs—were complied with (including whether payment by trust account rather than cash or LBP bonds complied with the statute).
Administrative procedure requirements and due process concerns
Administrative Order No. 12 prescribes a detailed identification process: MARO prepares a Compulsory Acquisition Case Folder (CACF), sends a notice of coverage and invitation to a conference to the landowner, prospective beneficiaries, BARC, LBP and others, records minutes, and forwards the completed folder to PARO. PARO computes valuation (with obligatory ocular inspection where value exceeds P500,000), forwards to DAR Central/BLAD, which reviews and prepares a notice of acquisition; if the owner rejects or fails to respond, DARAB conducts summary administrative proceedings to determine just compensation. The Court emphasized the importance of these steps as components of administrative due process before DAR may take possession and cause transfer of title.
Evidence bearing on watershed status and environmental considerations
Subsequent environmental studies and surveys (DENR/ERDB assessment of the Casile and Kabanga-an watersheds) established that the parcels are centrally situated within critical watersheds that feed the Matangtubig waterworks and that continued agricultural clearing, road building, and infrastructure could cause siltation, forest cover loss, and degradation of water supply and related life-support systems for thousands downstream. The ERDB report—prepared by qualified watershed specialists—recommended relocation and financial assistance for Casile farmers, declaration of the watersheds as critical and in need of rehabilitation, and formulation and implementation of a comprehensive watershed management plan in coordination with government agencies and the Canlubang Estate. DENR Secretary Alcala also recommended protecting and maintaining the area for watershed purposes and, if possible, allocating alternate lands for affected farmers.
Evidence bearing on zoning and slope exemption
Municipal zoning history: the parcels had previously been classified as "Park" by a 1979 municipal zoning ordinance (Housing and Land Use Regulatory Board certification). Sangguniang Bayan resolution in 1994 later voided that classification and declared the land agricultural. At DARAB hearings, SRRDC presented proof that portions of the Casile property had slopes of 18% and over, invoking the statutory exemption in Section 10 for lands with 18% slope and over (except already developed lands). These factual contentions therefore supported potential exemption from CARP coverage.
Payment procedure and legal requirement for just compensation
CARP conditions transfer of possession and title on the landowner’s receipt of corresponding payment or, in the owner’s rejection or non-response, on deposit by DAR of compensation in cash or in LBP bonds with an accessible bank. The Court noted that DAR had used a trust account mechanism (trust account opened by LBP) rather than payment in cash or the statutory deposit in cash or LBP bonds; this was inconsistent with the statutory procedure as interpreted by prior jurisprudence (Association of Small Landowners in the Philippines v. Secretary of Agrarian Reform). Thus there was a procedural defect in the manner of payment/deposit that required attention.
Court’s analysis and disposition
The Court recognized CARP as an exercise of both police power and eminent domain under the 1987 Constitution and underscored that takings require compliance with statutory procedures and just-compensation mechanisms. Given the substantial environmental and technical evidence demonstrating that the parcels form part of vit
...continue readingCase Syllabus (G.R. No. 112526)
Case Background and Subject Property
- Petitioner: Sta. Rosa Realty Development Corporation (SRRDC), registered owner of two contiguous parcels of land in Barangay Casile, Cabuyao, Laguna covered by Transfer Certificate of Title (TCT) Nos. 81949 and 84891.
- Total area of the two parcels as alleged by petitioner: 254.6 hectares (TCT Nos. 81949 and 84891).
- Petitioner’s assertions regarding the property:
- The parcels are watersheds that provide clean potable water to the Canlubang community.
- Ninety (90) light industries are located in the area.
- Respondents allegedly usurped petitioner’s rights over the property and destroyed the ecosystem.
- Petitioner contended the land is rugged with slopes of 18% and above and that occupants were squatters not entitled as beneficiaries.
Procedural History — Civil and Ejectment Actions
- December 1985: Respondents filed a civil case in the Regional Trial Court, Laguna seeking an easement of right of way to and from Barangay Casile (docketed as Civil Case No. B-2333).
- October 1986 to August 1987: Petitioner filed multiple forcible entry complaints in the Municipal Trial Court, Cabuyao, Laguna (Civil Cases Nos. 250, 258, 260, 262 and 266).
- Petitioner counterclaimed for ejectment in the civil case; later the RTC (Branch 24) rendered a decision (January 20, 1992, Civil Case No. B-2333) finding private respondents illegally entered and ordering eviction.
- Petitioner’s parallel efforts to resist occupation continued while compulsory acquisition proceedings unfolded administratively.
Initiation of CARP Compulsory Acquisition Process
- Respondents petitioned the Department of Agrarian Reform (DAR) for compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP) affecting SRRDC landholdings.
- August 11, 1989: Municipal Agrarian Reform Officer (MARO) of Cabuyao issued a notice of coverage to petitioner and invited officials/representatives to a conference scheduled August 18, 1989.
- Conference participants included: petitioner’s representatives, Land Bank of the Philippines (LBP), PARCCOM, PARO of Laguna, MARO of Laguna, BARC Chairman of Barangay Casile and some potential farmer-beneficiaries (residents of Barangay Casile).
- The assembly’s consensus/recommendation: SRRDC’s landholding be placed under compulsory acquisition.
- August 17, 1989: Petitioner filed a formal “Protest and Objection” with MARO, arguing the area was inappropriate for agricultural purposes due to rugged terrain and sloping of 18% and above and that occupants were squatters.
- August 29, 1989: Farmer-beneficiaries and BARC chairman answered petitioner’s protest, asserting slopes were only 5–10% and that the land was suitable and economically viable for agriculture; a Department of Agriculture, municipality of Cabuyao certification was cited to support suitability.
Administrative Case Folder Processing and Endorsements
- September 8, 1989: MARO Belen dela Torre made a summary investigation report and forwarded the Compulsory Acquisition Folder Indorsement (CAFI) to the Provincial Agrarian Reform Officer (PARO).
- September 21, 1989: PARO Durante Ubeda forwarded endorsement of compulsory acquisition to the Secretary of Agrarian Reform.
- November 23, 1989: Acting Director Eduardo C. Visperas of the Bureau of Land Acquisition and Development (BLAD), DAR forwarded two Compulsory Acquisition Claim Folders (for TCT Nos. 81949 and 84891) to the President, Land Bank of the Philippines for review and evaluation.
Notices of Acquisition, Protests, and Referral to DARAB
- December 12, 1989: Secretary Miriam Defensor Santiago sent two notices of acquisition to petitioner placing the landholdings under the CARP and valuing them:
- TCT No. 81949: 188.2858 hectares, valued at P4,417,735.65.
- TCT No. 84891: 58.5800 hectares, valued at P1,220,229.93.
- February 6, 1990: Petitioner sent formal protests to Secretary Florencio B. Abad and BLAD Director, contesting both the notices of acquisition and the offered compensation.
- March 17, 1990: Secretary Abad referred the matter to the Department of Agrarian Reform Adjudication Board (DARAB) for summary proceedings to determine just compensation under R.A. No. 6657, Section 16.
- March 23–28, 1990: LBP reported inability to value the property due to deficiencies in the claim folders; subsequent correspondence led to DARAB involvement and administrative valuation.
DARAB Proceedings — Early Steps and Requests
- May 10, 1990: BLAD Director Narciso Villapando turned the two claim folders over to the DARAB Executive Director for proper administrative valuation.
- September 10, 1990: DARAB promulgated a resolution requesting the Office of the Secretary of DAR to resolve two preliminary issues before summary land valuation:
- Whether the subject parcels fall within CARP compulsory acquisition coverage.
- Whether any petition for land conversion of the parcels may be granted.
- December 7, 1990: The Office of the Secretary (through Undersecretary for Operations and Regional Director, Region IV) reported:
- Issue 1: Notice of coverage (Aug. 11, 1989) and notice of acquisition (Dec. 12, 1989) placed the property under compulsory acquisition.
- Issue 2: Administrative Order No. 1, Series of 1990 supported DAR’s position on coverage; during Board consideration there was no pending petition for land conversion specifically concerning the parcels.
DARAB Administrative Hearing and Evidence Presented
- February 19, 1991: DARAB sent notice of hearing for administrative valuation, initially set for March 6, 1991; later moved to April 4, 1991 to allow petitioner to reconstruct records.
- March 18, 1991: SRRDC petitioned DARAB to resolve its petition for exemption from CARP coverage before valuation.
- April 4, 1991 onward: Initial DARAB hearing held; subsequent hearings occurred without objection from SRRDC counsel.
- April 15, 1991: SRRDC submitted a subdivision plan of the Casile property (marked as Exhibit “5”).
- April 23, 1991: LBP requested one month to value the land; a certification from the Deputy Zoning Administrator Generoso B. Opina (dated September 8, 1989) was presented, indicating the parcels had been classified as “industrial park” per Sanguniang Bayan Resolution No. 45-89 dated March 29, 1989.
- April 30, 1991: Petitioner filed a petition with DARAB to disqualify private respondents as beneficiaries; DARAB declined to address the beneficiary-qualification issue at that stage.
DARAB Decision (Decretal Portion) and Implementation Directives
- DARAB promulgated a decision (decretal portion quoted) ordering:
- Dismissal for lack of merit of petitioner’s protest against compulsory coverage for TCT Nos. 81949 and 84891 (254.766 hectares) under CARP.
- Land Bank of the Philippines to pay SRRDC the sum of P7,841,997.64 for its landholdings; if payment rejected, to open a trust account for said amount in SRRDC’s name.
- Register of Deeds of Laguna to cancel TCT Nos. 84891 and 81949 and issue new ones in the name of the Republic of the Philippines, free from liens and encumbrances.
- Department of Environment and Natural Resources (DENR) to conduct a final segregation survey to enable transfer of title to the Republic.
- Regional Office of DAR through Municipal and Provincial Agrarian Reform Offices to take immediate possession after title transfer and distribute land with immediate issuance of Emancipation Patents to farmer-beneficiaries as determined by MARO of Cabuyao, Laguna.
- DAR Secretary Benjamin T. Leong issued a memorandum (July 11, 1991) directing LBP to open a trust account in favor of SRRDC for P5,637,965.55 as valuation for the property (separate advisory/action preceding DARAB final decretal relief).
Court of Appeals Review and Disposition
- February 6, 1992: Petitioner filed a petition for review with the Court of Appeals (docketed CA-G.R. SP No. 27234).
- November 5, 1993: Court of Appeals promulgated a decision affirming DARAB’s decision; the decretal portion affirmed DARAB’s decision “without prejudice to petitioner Sta. Rosa Realty Development Corporation ventilating its case with the Special Agrarian Court on the issue of just compensation.”
Supreme Court Petition, Temporary Restraining Order and Bond
- November 24, 1993: Petitioner filed a petition for review on certiorari to the Supreme Court (G.R. No. 112526).
- December 8 and 13, 1993: The Court required petitioner to post a cash bond or surety bond of P1,500,000.00 for issuance of a temporary restraining order (TRO); petitioner posted a cash bond (Official Receipt No. 315519).
- December 15, 1993: The Supreme Court issued a Resolution granting the TRO which:
- Restrained DARAB from enforcing its December 19, 1991 decision and the Court of Appeals’ affirmance insofar as immediate possession, title transfer, distribution and issuance of Emancipation Patents were concerned.
- Specifically restrained DARAB, DAR, their agents, and private respondents from entering the properties, introducing permanent infrastructures, and private respondents from cutting or burning trees and vegetation on the properties pending further orders.
- The TRO remained in effect while the Supreme Court proceeded to resolve the petition; the Court later noted the TRO would continue until final decision.
Primary Legal Issues Presented
- Whether the subject parcels of land are covered by CARP for compulsory acquisition despite assertions they formed part of a protected watershed area prior to R.A. No. 6657.
- Whether parcels are exempt or excluded from CARP coverage by reason of watershed classification, other exempt uses, or on account of slopes of 18% and over (R.A. No. 6657, Section 10).
- Whether DAR’s procedural acts in effecting the taking, and the method of payment to the landowner, complied with the procedures and requirements of R.A. No. 6657, particularly Section 16 (notice, acceptance, summary proceedings, determination and deposit/payment of compensation, and transfer of title).
- Whether the initial zoning/classification as “Park” or “Industrial Park” by municipal action affected CARP cove