Reyes v. Garilao
REITERATIONFacts
The Antecedents: Petitioners, the heirs of Aurelio Reyes, are the registered co-owners of a 99.1085-hectare parcel of land in Orani, Bataan. The original owners were spouses Antonia and Aurelio Reyes. Aurelio Reyes died before the effectivity of Presidential Decree No. 27, and the property passed by succession to the petitioners. On September 21, 1988, emancipation patents were issued to respondents as farmer-beneficiaries over the entire landholding. Procedural History: On July 15, 1993, petitioners filed applications for retention of five hectares each under Republic Act No. 6657. On October 25, 1994, the OIC-Regional Director granted these applications. However, on November 30, 1996, the DAR Secretary reversed this order, revoking the retention rights based on findings that the heirs owned other non-agricultural lands in Makati and Manila, from which they derived adequate income. The Court of Appeals (CA) affirmed the DAR Secretary's decision on April 16, 1997, and denied reconsideration on December 2, 1998. The Petition: Petitioners seek review on certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution. They argue that their right to retention is not foreclosed by any vested right of the respondents, that Letter of Instruction (LOI) No. 474 has been repealed by RA No. 6657, and that DAR Administrative Order No. 4, series of 1991, lacks statutory basis as it applies only to retention rights under PD No. 27. The core of their argument is that RA No. 6657 does not contain the restrictive conditions found in LOI No. 474.
Issue(s)
Whether Letter of Instruction No. 474 (LOI 474) and DAR Administrative Order No. 4, series of 1991, imposing restrictions on retention rights, apply to applications for retention under Republic Act No. 6657 (RA 6657). Whether RA 6657 impliedly repealed LOI 474. Whether DAR Administrative Order No. 4, series of 1991, has a statutory basis. Whether there is substantial evidence to support the finding that petitioners own other lands devoted to non-agricultural uses from which they derive adequate income.
Ruling
The petition is denied. The April 16, 1997 Decision and December 2, 1998 Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the applicability of LOI 474 and DAR AO 4, series of 1991, to RA 6657: The Court held that LOI No. 474, which imposes restrictive conditions on the exercise of retention rights by landowners who own other agricultural lands or lands used for residential, commercial, industrial, or other urban purposes from which they derive adequate income, applies suppletorily to RA No. 6657. While RA 6657 provides for a retention limit of five hectares, it does not explicitly contain the limitations found in LOI 474. However, the Court found no conflict between the two laws, as they can be given effect. The suppletory application of existing legislation is sanctioned under Section 75 of RA 6657. Therefore, landowners are entitled to retain five hectares, but if they own other lands used for non-agricultural purposes from which they derive adequate income, they are disqualified from exercising their right of retention. On the implied repeal of LOI 474 by RA 6657: The Court disagreed with the petitioners' theory that RA 6657 impliedly repealed LOI 474. Implied repeals are not favored and will not be declared unless the intent of the legislature is manifest. The congressional deliberations cited by petitioners were confined to retention limits and did not mention the restrictive conditions in LOI 474. The Court found no clear intent to repeal LOI 474, and thus, the later general law (RA 6657) should be construed as a continuation of, and not a substitute for, the earlier special law (LOI 474). On the statutory basis of DAR Administrative Order No. 4, series of 1991: The Court affirmed the validity of DAR Administrative Order No. 4, series of 1991. Administrative regulations and policies enacted by administrative bodies to interpret the law they are entrusted to enforce have the force of law. Since the validity of LOI 474 and its suppletory application to RA 6657 were settled, DAR Administrative Order No. 4, series of 1991, which reiterates the conditions in LOI 474, is valid. On the substantial evidence of other landholdings: The Court upheld the DAR Secretary's findings that petitioners owned other landholdings in Makati and Manila used for non-agricultural purposes from which they derived adequate income. These findings were affirmed by the CA and are considered questions of fact that cannot be the subject of a petition for review. The Court accorded finality to the DAR's findings due to its acquired expertise and found them to be supported by substantial evidence, which is sufficient in agrarian cases.
Main Doctrine
Letter of Instruction No. 474, which imposes restrictive conditions on the exercise of retention rights by landowners who own other lands used for residential, commercial, industrial, or other urban purposes from which they derive adequate income, applies suppletorily to Republic Act No. 6657, even though RA 6657 does not explicitly contain such restrictions. A general law does not repeal a prior special law unless the intent to repeal is manifest.