Roxas & Company, Inc. v. Damayan ng mga Manggagawang Bukid sa Asyenda Roxas-National Federation of Sugar Workers
REITERATIONFacts
The Antecedents: Petitioner Roxas & Company, Inc. (Roxas & Co.) sought the conversion of its three haciendas in Nasugbu, Batangas, from agricultural to non-agricultural use. Roxas & Co. contended that Presidential Proclamation No. 1520 (PP 1520), issued in 1975, declared these municipalities a tourist zone, thereby reclassifying all lands within them to non-agricultural use, exempting them from the Comprehensive Agrarian Reform Program (CARP). The Department of Agrarian Reform (DAR) issued Certificates of Land Ownership Award (CLOAs) to farmer-beneficiaries on these haciendas. Procedural History: Roxas & Co. filed applications for conversion and exemption with the DAR. The DAR denied the applications, finding that PP 1520 did not automatically reclassify the lands and that specific areas for tourism development had not been identified. Roxas & Co. appealed to the Court of Appeals, which initially ruled in its favor, declaring the lands exempt. However, subsequent proceedings and appeals led to the consolidation of seven petitions before the Supreme Court. The Petition: The consolidated petitions primarily questioned whether PP 1520 reclassified the lands to non-agricultural use, whether a local zoning ordinance exempted certain parcels, and the validity of DAR's cancellation of CLOAs. Roxas & Co. argued that PP 1520's declaration of a tourist zone inherently meant non-agricultural use, citing similar presidential proclamations and jurisprudence. Conversely, respondents argued that PP 1520 merely identified potential tourism areas and did not effect an automatic reclassification, requiring further action by the Philippine Tourism Authority (PTA). They also contested the validity of CLOA cancellations and raised issues of forum shopping.
Issue(s)
Whether Presidential Proclamation No. 1520 reclassified in 1975 all lands in the Maragondon-Ternate-Nasugbu tourism zone to non-agricultural use to exempt Roxas & Co.'s three haciendas from CARP coverage. Whether Nasugbu Municipal Zoning Ordinance No. 4, Series of 1982, exempted certain lots in Hacienda Palico from CARP coverage. Whether the partial and complete cancellations by the DAR of CLOA No. 6654, subject of G.R. No. 167505, are valid. Whether Roxas & Co. committed forum shopping.
Ruling
The Supreme Court ruled that Presidential Proclamation No. 1520 did not automatically convert agricultural lands to non-agricultural uses. It clarified that the proclamation required the Philippine Tourism Authority (PTA) to identify specific geographic areas for tourism development. The Court affirmed that certain lots in Hacienda Palico were indeed reclassified to non-agricultural use by the Nasugbu Municipal Zoning Ordinance No. 4, Series of 1982, prior to CARL's effectivity, thus exempting them from CARP coverage. The Court also ordered the cancellation of CLOAs for specific lots in Hacienda Palico due to their exemption, while upholding the validity of other CLOAs. Roxas & Co. was ordered to pay disturbance compensation for the affected farmer-beneficiaries. The Court found no forum shopping.
Ratio Decidendi
On Whether Presidential Proclamation No. 1520 reclassified lands to non-agricultural use: The Court held that Presidential Proclamation No. 1520 (PP 1520) did not automatically reclassify all agricultural lands within the declared tourist zones to non-agricultural uses. The proclamation merely declared the municipalities as a tourist zone and directed the Philippine Tourism Authority (PTA) to identify specific geographic areas with potential tourism value. The Court reasoned that if the intention was a blanket reclassification, there would be no need for the PTA to identify specific areas. The Court distinguished PP 1520 from other proclamations that provided technical descriptions or explicitly converted lands for specific non-agricultural uses, citing jurisprudence like Natalia Realty, Inc. v. DAR and NHA v. Allarde as not being directly applicable due to the general nature of PP 1520. The Court emphasized that the CARL's coverage is limited to agricultural lands, and lands already classified as non-agricultural before its effectivity do not need conversion clearance. On whether Nasugbu Municipal Zoning Ordinance No. 4 exempted certain lots: The Court found that Nasugbu Municipal Zoning Ordinance No. 4, Series of 1982, which was approved by the Human Settlements Regulation Commission (now HLURB), did reclassify certain lots in Hacienda Palico to non-agricultural uses. However, Roxas & Co. failed to definitively identify the specific lots subject to this ordinance due to discrepancies in titles and certifications, leading to the denial of exemption for some lots. For other lots (DAR Administrative Case No. A-9999-008-98), the Court granted the exemption based on substantial compliance with the requirements, including certifications from local planning and zoning administrators and HLURB, confirming their classification as non-agricultural prior to CARL's effectivity. On the validity of CLOA cancellations: The Court ruled that the CLOAs issued for nine parcels of land in Hacienda Palico (DAR Administrative Case No. A-9999-008-98), which were found to be exempt from CARP coverage due to the municipal zoning ordinance, must be cancelled. This cancellation was contingent upon Roxas & Co. first paying the required disturbance compensation to the farmer-beneficiaries. The Court also set aside a PARAD decision ordering the total cancellation of CLOA No. 6654, except for the specific lots that were found to be exempt, thereby affirming the partial cancellation. The Court reiterated that the failure to comply with due process in acquisition proceedings does not automatically nullify CLOAs, but the DAR must be given a chance to correct procedural lapses, which can lead to cancellation if the land is found exempt. On forum shopping: The Court found no forum shopping on the part of Roxas & Co. It explained that the various cases filed involved different legal bases, factual circumstances, and sought distinct reliefs, falling under the separate jurisdictions of the DAR Secretary (for exemption applications) and the DAR Adjudication Board (for CLOA cancellations). The Court noted that administrative bodies are given wide latitude in evaluating evidence, and the presumption of regularity in the performance of official duties applies to the certifications submitted by Roxas & Co. supporting its exemption claims.
Main Doctrine
Presidential Proclamation No. 1520, which declared certain municipalities as tourist zones, did not automatically reclassify all agricultural lands within those zones to non-agricultural uses. The proclamation required the Philippine Tourism Authority to identify specific geographic areas with potential tourism value. Furthermore, lands already classified as non-agricultural by valid local government zoning ordinances prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL) on June 15, 1988, are exempt from CARP coverage.