De Guzman v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioners Froilan De Guzman, Angel Marcelo, and Nicasio Magbitang were tenants on a six-hectare parcel of land in Baliuag, Bulacan, formerly owned by the Vergel De Dios family. In 1979, the Municipality of Baliuag initiated expropriation proceedings for this land. During these proceedings, the municipality and the petitioners entered into a compromise agreement wherein the petitioners irrevocably withdrew their opposition to the expropriation in exchange for a disturbance compensation of P25,000.00 per hectare and waived all other claims against the municipality. This agreement was approved by the Court of Agrarian Relations. The municipality acquired the land and allowed the petitioners to continue cultivating their lots pending the construction of a wholesale market complex, with petitioners remitting rentals. However, the market construction never materialized. Procedural History: In 1996, the petitioners filed a petition with the Municipal Agrarian Reform Office (MARO) of Baliuag, seeking to have the land covered under the Operation Land Transfer (OLT) program, pursuant to Presidential Decree No. 27. Subsequently, on May 13, 1997, they filed a complaint with the Department of Agrarian Reform Adjudication Board (DARAB) against the municipality, seeking injunctive relief to maintain their peaceful possession. The Provincial Adjudicator ruled in favor of the petitioners, declaring them bona fide farmer-beneficiaries and directing the municipality to cease dumping garbage and maintain their possession. On January 6, 1997, the DAR Regional Director issued an order granting the petition for OLT coverage. The municipality's motion for reconsideration was denied, and its subsequent appeal to the DAR Secretary resulted in a reversal of the Regional Director's order on August 8, 1997. The petitioners appealed this decision to the Office of the President, which, on July 1, 1999, dismissed their appeal and affirmed the DAR Secretary's order. The petitioners then filed a petition for review with the Court of Appeals, which affirmed the Office of the President's decision on January 30, 2002, and denied the subsequent motion for reconsideration on January 20, 2003. The Petition: Petitioners seek review of the Court of Appeals' decision and resolution via a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure. They contend that the Court of Appeals erred in upholding the reclassification of the land as non-agricultural, arguing that the land should have been covered by Operation Land Transfer due to the landowner's failure to implement its conversion for a long period. They also argue that the Court of Appeals disregarded Administrative Order No. 20, series of 1992, which they claim disallows the conversion of irrigated prime agricultural lands for non-agricultural purposes. The core of their argument is that the failure to realize the commercial project should have reverted the land to its agricultural status, thereby making it subject to agrarian reform laws.
Issue(s)
Whether the subject landholding should have been covered by Operation Land Transfer pursuant to P.D. No. 27, considering the landowner's failure to convert it from agricultural land for a long period, and the effect of prior reclassification. Whether the Court of Appeals erred in upholding the reclassification of the subject landholding, particularly regarding its classification as commercial land under R.A. No. 6657. Whether the Court of Appeals committed grave abuse of discretion by disregarding the provisions of O.P. Administrative Order No. 20, series of 1992, and whether this administrative order applies retroactively.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of OLT coverage and failure to convert: The Court held that lands not devoted to agricultural activity are outside the coverage of the Comprehensive Agrarian Reform Law (CARL), including lands previously converted to non-agricultural uses by government agencies other than the DAR, even if the conversion purpose did not materialize. The municipality passed a zoning ordinance in 1980 identifying the land as a site for a wholesale market complex, and the HLURB certified it as within an approved zoning plan. This reclassification effectively removed the land from the agricultural status. The subsequent failure to construct the market complex did not revert the land to its agricultural status, especially considering the amendments to R.A. No. 3844 which removed the requirement for landowners to implement conversion within a specific period. On the reclassification of the subject landholding: The Court affirmed the non-agricultural classification of the land. Under Section 3(c) of R.A. No. 6657, agricultural land does not include lands classified as commercial. The zoning ordinance passed by the municipality in 1980, identifying the land as a commercial site, was sufficient to classify it as non-agricultural. This classification was recognized by the HLURB. The fact that petitioners continued to cultivate the land after its expropriation and reclassification was considered to be by mere tolerance of the municipality, not indicative of its agricultural status. On the application of A.O. No. 20, series of 1992: The Court ruled that Administrative Order No. 20, series of 1992, which sets guidelines for agricultural land use conversion, cannot be applied retroactively to the subject land. The land had already been classified as commercial long before the issuance of A.O. No. 20. Therefore, the provisions of this administrative order, which disallow conversion of prime agricultural lands, were not applicable to the present case. The power of local government units to adopt zoning ordinances for land reclassification is also recognized and is not subject to the approval of the Department of Agrarian Reform.
Main Doctrine
A land classified as non-agricultural prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL), even if its conversion purpose did not materialize, is outside the coverage of CARL. The power of local government units to adopt zoning ordinances for land reclassification is recognized and is not subject to the approval of the Department of Agrarian Reform.