Department of Agrarian Reform v. Department of Education, Culture and Sports
REITERATIONFacts
The Antecedents: Lot No. 2509 and Lot No. 817-D, with an aggregate area of 189.2462 hectares, were donated to the Department of Education, Culture and Sports (DECS) on October 21, 1921. These lands were subsequently leased by DECS to Anglo Agricultural Corporation for two 10-year agricultural crop years. On June 10, 1993, Eugenio Alpar and others, claiming to be farm workers, filed a petition for Compulsory Agrarian Reform Program (CARP) coverage. Procedural History: The Municipal Agrarian Reform Office (MARO) issued a "Notice of Coverage." The DAR Regional Director approved the coverage, which was affirmed by the Secretary of Agrarian Reform. The Court of Appeals reversed the decision of the Secretary of Agrarian Reform. This petition for review on certiorari seeks to set aside the Court of Appeals' decision. The Petition: The Department of Agrarian Reform (DAR) petitions this Court to reverse the Court of Appeals' decision, arguing that the subject properties are not exempt from CARP coverage.
Issue(s)
Whether the subject properties are exempt from the coverage of Republic Act No. 6657 (CARL). Whether the farmers are qualified beneficiaries of CARP.
Ruling
The petition is GRANTED. The decision of the Court of Appeals dated October 29, 2002, in CA-G.R. SP No. 64378 is REVERSED and SET ASIDE. The decision dated August 30, 2000, of the Secretary of Agrarian Reform placing the subject lands under CARP coverage, is REINSTATED.
Ratio Decidendi
On whether the subject properties are exempt from the coverage of Republic Act No. 6657 (CARL): The Court held that for a land to be exempt under Section 10(c) of R.A. No. 6657, it must be "actually, directly, and exclusively used and found to be necessary" for school sites and campuses. The Court emphasized the literal and technical definitions of these words, applying the "plain meaning rule" (verba legis). In this case, the lands were leased to Anglo Agricultural Corporation not for educational purposes but for its business, and it was the income from the lease, not the land itself, that was used for school repairs. This distinguishes the case from Central Mindanao University v. Department of Agrarian Reform Adjudication Board, where the land was reserved for educational purposes and its use, even by a corporation, was tied to the university's research program. The subject lands in this case were classified as alienable and disposable lands of the public domain suitable for agriculture and were not actually and exclusively utilized as school sites. On whether the farmers are qualified beneficiaries of CARP: The Court disagreed with the Court of Appeals' finding that the farmers were not qualified beneficiaries. It stated that the identification and selection of CARP beneficiaries are vested in the Secretary of Agrarian Reform, pursuant to Section 15 of R.A. No. 6657. The records showed that the Barangay Agrarian Reform Committee (BARC) certified the farmers as potential beneficiaries, and the DAR issued a Notice of Coverage. The Court cautioned that courts should exercise great caution in substituting their judgment on such administrative matters unless there is grave abuse of discretion, which was not present in this case. The Court reiterated that CARP is a mechanism for social justice for landless farmers and farmworkers.
Main Doctrine
Lands owned by the government, even if leased for agricultural purposes, are covered by the Comprehensive Agrarian Reform Program (CARP) unless they are actually, directly, and exclusively used and found to be necessary for school sites and campuses. The income derived from the lease of such lands, if not used for educational purposes, does not exempt the land itself from CARP coverage.