Pasong Bayabas Farmers Association, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: Credito Asiatic, Inc. (CAI) acquired a 75.36-hectare property in Carmona, Cavite. The property was intended for development into a residential and industrial estate, including the Tamanli Housing Project. Various government agencies, including the Municipal Council of Carmona, the National Planning Commission, and the Ministry of Agrarian Reform (under Minister Conrado F. Estrella), approved the conversion of portions of the land from agricultural to residential use between 1976 and 1979. CAI secured necessary permits and licenses for housing projects like Hakone Subdivision, Sunshine Village, and Mandarin Homes. In 1987, a civil case was filed by alleged tillers claiming they were cultivating the land and were surreptitiously deprived of their rights due to the conversion. This case was eventually dismissed after a compromise agreement and quitclaims were executed by most plaintiffs. In 1992, a petition for compulsory coverage under Republic Act No. 6657 (CARL) was filed by individuals claiming to be farmers. Subsequently, the Pasong Bayabas Farmers Association, Inc. (PBFAI) filed a petition for compulsory coverage of a portion of CAI's property. In 1995, CAI commenced bulldozing and development activities, leading PBFAI to file a complaint for Maintenance of Peaceful Possession and Cultivation with Damages before the Department of Agrarian Reform Adjudication Board (DARAB). Procedural History: The Provincial Agrarian Reform Adjudicator (PARAD) dismissed PBFAI's complaint, finding that some plaintiffs had abandoned their tenancy rights and were barred by res judicata, while others were not bona fide tenants but mere interlopers. The PARAD also declined to resolve issues of coverage under CARL and the legality of conversion, citing lack of jurisdiction. The DARAB reversed the PARAD's decision, declaring the land within CARP coverage and ordering steps for acquisition and distribution to farmer-beneficiaries. The Court of Appeals (CA) then reversed the DARAB, reinstating the PARAD's decision, holding that the land was exempt from CARL coverage due to its slope and prior reclassification as residential. The CA cited the authority of local government units to reclassify lands and the ruling in Fortich v. Corona. The Petition: PBFAI and the DARAB filed petitions for review on certiorari before the Supreme Court, assailing the CA's decision. The core issues revolved around whether the property was covered by CARL, the jurisdiction of DARAB, the existence of a cause of action for possession and cultivation, the effect of the prior RTC dismissal, and whether the CA committed reversible error.
Issue(s)
Whether the property subject of the suit is covered by Republic Act No. 6657 (CARL). Whether the DARAB had original and appellate jurisdiction over the complaint of PBFAI. Whether the members of PBFAI have a cause of action against CAI for possession and cultivation of the property, considering prior abandonment and quitclaims. Whether the dismissal by the RTC of the complaint in Civil Case No. BCV-87-13 is a bar to the complaint of PBFAI members, raising issues of res judicata and waiver; and whether the Court of Appeals committed a reversible error in dismissing the petition for review, considering prior valid reclassifications and conversions. Whether CAI's counterclaim for damages should be granted.
Ruling
The Supreme Court denied the petitions, affirmed the Court of Appeals' decision with modifications, dismissed PBFAI's complaint, dismissed CAI's counterclaim, and ordered the members of PBFAI and all those occupying the property to vacate the landholding.
Ratio Decidendi
On the issue of whether the property is covered by CARL: The Court ruled that the property was not covered by Republic Act No. 6657 (CARL). It found that the land had been reclassified and converted from agricultural to non-agricultural or residential land by various government agencies long before CARL's effectivity on June 15, 1988. These agencies included the Bureau of Lands, the National Planning Commission, the Municipal Council of Carmona (Resolution No. 30, May 30, 1976), the Ministry of Agrarian Reform (Order dated July 3, 1979), the Ministry of Local Government and Community Development, the Human Settlements Regulatory Commission (HSRC), and the Housing and Land Use Regulatory Board (HLURB). The Court emphasized that lands not devoted to agricultural activity, including those previously converted to non-agricultural uses by government agencies other than DAR prior to CARL's effectivity, are outside its coverage. The Court also noted that the property had an 18% slope, which, under Section 10 of CARL, exempts undeveloped lands with such a slope from its coverage, unless already developed. On the issue of DARAB's jurisdiction: Consequently, since the property was determined to be non-agricultural and outside CARL's coverage, the DARAB had no original and appellate jurisdiction over the complaint filed by PBFAI and its members. The Court reiterated that the jurisdiction of a tribunal is determined by the averments of the complaint and the law at the time of filing. As the subject land was already classified as residential prior to June 15, 1988, it did not require conversion clearance from the DAR. The Court found that the DARAB acted with grave abuse of discretion amounting to excess or lack of jurisdiction in declaring the property as agricultural land and reversing the PARAD's decision. On the issue of PBFAI members' cause of action, considering prior abandonment and quitclaims: The Court found that PBFAI members did not have a cause of action against CAI for possession and cultivation because there was no established tenancy relationship. The Court cited the PARAD's findings that some plaintiffs had abandoned their rights through quitclaims and compromise agreements, while others were mere interlopers or farm helpers without a valid agricultural tenancy. Furthermore, the execution of deeds of quitclaim by a significant number of PBFAI members waived their claims over the property, negating any right to continued possession. On the issue of the effect of prior dismissal and the Court of Appeals' error: The prior dismissal of a similar case by the RTC was considered, as it involved many of the same parties or their kin, and involved the same subject matter, raising issues of res judicata and waiver. The Court found no reversible error committed by the Court of Appeals. The CA correctly applied the principle that local government units need not obtain DAR approval to convert or reclassify lands from agricultural to non-agricultural use, as established in cases like Fortich v. Corona. The CA also correctly considered the exemption provided by Section 10 of CARL for lands with an 18% slope. The DARAB's reversal of the PARAD's decision was deemed an error, as it effectively overturned prior valid reclassifications and conversions made by competent authorities. On the dismissal of the counterclaim: The Court dismissed CAI's counterclaim for damages. While CAI incurred expenses for development, the dismissal was likely due to the overall outcome of the case, which focused on the lack of jurisdiction and the absence of a valid claim by PBFAI, rather than a finding of merit in CAI's counterclaim for damages against the farmers.
Main Doctrine
Lands already classified as non-agricultural (residential, commercial, or industrial) prior to the effectivity of Republic Act No. 6657 (CARL) do not need conversion clearance from the Department of Agrarian Reform (DAR) and are thus outside the coverage of CARL. The authority of local government units to reclassify lands from agricultural to non-agricultural use, when exercised within their police power and in accordance with law, is not subject to the approval of the DAR.