Atlas Fertilizer Corporation v. Secretary of the Department of Agrarian Reform
REITERATIONFacts
1. The Antecedents: Petitioners Atlas Fertilizer Corporation and Philippine Federation of Fishfarm Producers, Inc., along with petitioner-in-intervention Archie's Fishpond, Inc. and Arsenio Al. Acuna, are engaged in the aquaculture industry, specifically operating fishponds and prawn farms. They challenge the constitutionality of several provisions within Republic Act No. 6657, known as the Comprehensive Agrarian Reform Law (CARL), and its implementing guidelines. 2. Procedural History: The case involves consolidated petitions that question the constitutionality of portions of R.A. 6657. The petitioners argue that the law, as applied to aquaculture lands, violates constitutional provisions concerning the scope of agrarian reform, equal protection, and the rights of enterprises. The Supreme Court notes that a similar issue regarding the inclusion of livestock, poultry, and swine lands was addressed in Luz Farms, Inc. v. Secretary of Agrarian Reform. The present petitions specifically focus on the inclusion of aquaculture lands, such as fishponds and prawn farms, within CARL's coverage. 3. The Petition: Petitioners assail Sections 3(b), 11, 13, 16(d), 17, and 32 of R.A. 6657, along with Administrative Order Nos. 8 and 10 Series of 1988. They argue these provisions unconstitutionally extend agrarian reform to aquaculture lands, which they contend are not agricultural lands as defined by the Constitution. They also claim violations of equal protection and the right to freedom of enterprise. However, the Court notes that Republic Act No. 7881, enacted during the pendency of these petitions, amended CARL by explicitly exempting private lands used for prawn farms and fishponds from its coverage, rendering the constitutional questions moot and academic.
Issue(s)
Whether Sections 3(b), 11, 13, 16(d), 17, and 32 of R.A. 6657, and Administrative Order Nos. 8 and 10 Series of 1988, are unconstitutional for extending agrarian reform to aquaculture lands. Whether the inclusion of aquaculture lands in CARL violates the equal protection clause. Whether the case has become moot and academic due to subsequent legislation.
Ruling
The petition is dismissed. The question concerning the constitutionality of the assailed provisions has become moot and academic with the passage of Republic Act No. 7881.
Ratio Decidendi
On the constitutionality of CARL provisions concerning aquaculture lands: The Court noted that the constitutionality of similar provisions of CARL, concerning lands devoted to livestock, poultry, and swine, had already been ruled upon in Luz Farms, Inc. v. Secretary of Agrarian Reform. The present petitions specifically question the inclusion of lands devoted to the aquaculture industry, particularly fishponds and prawn farms. Petitioners argued that, similar to livestock lands, aquaculture lands should be excluded because the use of land is incidental and not the principal factor in productivity, and that there are no farmers or farm workers tilling the land, thus no agrarian unrest. They also contended that aquaculture lands are industrial lands and not agricultural lands as contemplated by the Constitution. On the equal protection clause argument: Petitioners contended that treating aquaculture lands the same as agricultural lands violates the equal protection clause, asserting that aquaculture lands are industrial lands and should have been excluded by the framers of the Constitution. They pointed to the debates in the Constitutional Commission which they believed showed an intent to exclude industrial lands. On the mootness of the issue: The Court observed that Republic Act No. 7881, approved on February 20, 1995, amended certain provisions of R.A. No. 6657. Specifically, Section 1 of R.A. No. 7881 amended Section 3(b) of CARL, and Section 2 thereof amended Section 10 of CARL by explicitly stating that private lands actually, directly, and exclusively used for prawn farms and fishponds shall be exempt from the coverage of CARL, subject to certain conditions. Furthermore, Section 3 of R.A. No. 7881 amended Section 11 of CARL, redefining commercial farms and excluding fishponds and prawn ponds from its immediate compulsory acquisition and distribution. The Court concluded that in view of these amendments, the question concerning the constitutionality of the assailed provisions of CARL has become moot and academic.
Main Doctrine
The passage of Republic Act No. 7881, which expressly excludes fishponds and prawn farms from the coverage of the Comprehensive Agrarian Reform Law (CARL), renders moot and academic the constitutional challenge against the provisions of CARL that included aquaculture lands.