Roxas & Company, Inc. v. Damayan ng mga Manggagawang Bukid sa Asyenda Roxas-National Federation of Sugar Workers
REITERATIONFacts
The Antecedents: Roxas & Company, Inc. (Roxas & Co.) sought the conversion of its three haciendas in Nasugbu, Batangas, from agricultural to non-agricultural use. The core of the dispute revolved around whether Presidential Proclamation No. 1520, issued in 1975, which declared Nasugbu as a tourist zone, automatically reclassified these lands as non-agricultural, thereby exempting them from the coverage of the Comprehensive Agrarian Reform Law (CARL) of 1988. Roxas & Co. also invoked Nasugbu Municipal Zoning Ordinance No. 4, Series of 1982, for the exemption of specific parcels within Hacienda Palico. Procedural History: Roxas & Co. filed applications for conversion and exemption with the Department of Agrarian Reform (DAR). The DAR initially denied these applications, finding that Presidential Proclamation No. 1520 did not automatically reclassify the lands and that the identity of the parcels claimed to be reclassified by the municipal ordinance was not sufficiently established. These denials were appealed to the Court of Appeals, which rendered conflicting decisions. Ultimately, seven consolidated petitions reached the Supreme Court. The Petition: The consolidated petitions primarily questioned whether Presidential Proclamation No. 1520 reclassified the lands in Nasugbu to non-agricultural use, whether the Nasugbu Municipal Zoning Ordinance No. 4 exempted certain lots from CARP coverage, and whether the DAR's cancellation of Certificates of Land Ownership Award (CLOAs) was valid. Roxas & Co. argued for exemption based on the presidential proclamation and the municipal ordinance, while farmer-beneficiary groups (DAMBA-NFSW, KAMAHARI) and the DAR argued against automatic reclassification and for CARP coverage.
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 reclassify all agricultural lands in the declared tourism zones to non-agricultural use. The Court affirmed that specific identification of areas for tourism development by the Philippine Tourism Authority (PTA) was necessary. However, the Court granted exemption for certain lots in Hacienda Palico based on the Nasugbu Municipal Zoning Ordinance No. 4, Series of 1982, finding substantial compliance with the requirements for exemption. The Court also ordered the cancellation of certain CLOAs due to the exemption of the underlying lands, while upholding the right to disturbance compensation for affected farmer-beneficiaries. The Court found no forum-shopping on the part of Roxas & Co.
Ratio Decidendi
On Whether Presidential Proclamation No. 1520 reclassified lands to non-agricultural use: The Court clarified that Presidential Proclamation No. 1520, which declared municipalities as a tourist zone, did not automatically reclassify all agricultural lands within those zones to non-agricultural uses. The proclamation mandated the Philippine Tourism Authority (PTA) to identify specific geographic areas with potential tourism value. The Court distinguished this from cases where presidential proclamations or zoning ordinances provided clear technical descriptions or specific reclassifications. The Court held that the proclamation's intent was to designate the entire area for tourism development, but the actual reclassification required further action by the PTA. On Whether Nasugbu Municipal Zoning Ordinance No. 4 exempted certain lots: The Court found that certain lots in Hacienda Palico were indeed exempt from CARP coverage based on Nasugbu Municipal Zoning Ordinance No. 4, Series of 1982, which reclassified them to non-agricultural uses prior to the effectivity of the CARL. The Court considered the certifications from the Municipal Planning and Development Coordinator and the Housing and Land Use Regulatory Board (HLURB) as substantial evidence of this reclassification. The Court noted that the ordinance, enacted in 1982 and approved by the HLURB in 1983, predated the CARL's effectivity in 1988. On the validity of CLOA cancellations: The Court ordered the cancellation of CLOAs for lands that were validly exempted from CARP coverage due to reclassification. The Court reasoned that if the land itself was not subject to CARP, then the CLOAs issued over it were erroneously issued and should be cancelled. However, the Court emphasized that farmer-beneficiaries were entitled to disturbance compensation as mandated by law before their dispossession. 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, subject matters, and reliefs sought, and were filed in different forums with distinct jurisdictions (e.g., DAR Secretary for exemption applications, DARAB for CLOA cancellations). The Court noted that these were distinct administrative processes required by law, not attempts to relitigate the same issues in multiple forums.
Main Doctrine
Presidential Proclamations declaring general areas as tourist zones do not automatically reclassify all agricultural lands within those zones to non-agricultural uses. Instead, such proclamations require the Philippine Tourism Authority (PTA) to identify specific geographic areas with potential tourism value. Lands already classified as non-agricultural by valid municipal zoning ordinances prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL) on June 15, 1988, are exempt from CARP coverage, provided their identity and location are clearly established.