Luna v. Afable
REITERATIONFacts
The Antecedents: Petitioners are co-owners of a 158.77-hectare parcel of land in Oriental Mindoro. In 1998, approximately 100 hectares of this landholding were subjected to compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP), with Certificates of Land Ownership Award (CLOAs) subsequently issued to identified farmer-beneficiaries. The petitioners challenged this acquisition, asserting that the land had been reclassified as non-agricultural prior to the effectivity of Republic Act No. 6657 (the CARL), and thus was outside the CARP's coverage. Procedural History: The petitioners initially filed a petition with the DAR Adjudication Board (DARAB) seeking the cancellation of the CLOAs, arguing that Municipal Ordinance No. 21 of 1981 had reclassified the land into a light industrial zone. The DARAB Calapan City initially ruled in favor of the petitioners, declaring the land exempt from CARP. However, the DARAB Central Office reversed this, stating that an exemption clearance from the DAR was still required. Consequently, the petitioners applied for and were initially granted an exemption by DAR Secretary Pagdanganan in 2003. This was later revoked by DAR OIC-Secretaries Ponce and Pangandaman, who found the land to be still agricultural. The Office of the President, in turn, reinstated Secretary Pagdanganan's exemption order. The respondents then appealed to the Court of Appeals (CA), which reversed the Office of the President's decision, reinstating the DAR OIC-Secretaries' rulings. This petition for review on certiorari before the Supreme Court followed. The Petition: This is a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the Court of Appeals' decision. The petitioners argue that the CA erred in finding that the Office of the President's decision was not supported by substantial evidence. The core issue is whether the subject landholding was reclassified as non-agricultural by Municipal Ordinance No. 21 of 1981, enacted prior to the effectivity of the CARL on June 15, 1988, thereby exempting it from CARP coverage. Petitioners contend that the ordinance, as approved by the Housing and Land Use Regulatory Board (HLURB) in 1980, validly reclassified the area, and subsequent certifications from zoning administrators confirm its industrial classification, making it outside the scope of agrarian reform.
Issue(s)
Whether the subject landholding was validly reclassified as non-agricultural prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL) on June 15, 1988, thereby exempting it from the coverage of the Comprehensive Agrarian Reform Program (CARP).
Ruling
The Court GRANTS the petition, REVERSES and SETS ASIDE the Decision and Resolution of the Court of Appeals, and REINSTATES the Decision of the Office of the President dated December 15, 2006.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the land is exempt from CARP because it was validly reclassified into a light intensity industrial zone by the Municipality of Calapan through Ordinance No. 21 in 1981. Applying the doctrine in Natalia Realty, Inc. v. Department of Agrarian Reform, the Court emphasized that lands not devoted to agricultural activity, including those converted to non-agricultural uses by government agencies other than the Department of Agrarian Reform (DAR) prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL), are outside its scope. The Court noted that the power of local government units to reclassify agricultural land under Section 3 of Republic Act (RA) No. 2264 (The Local Autonomy Act of 1959) was absolute prior to June 15, 1988. Since the zoning ordinance was approved by the Housing and Land Use Regulatory Board (HLURB) in 1980, the two-pronged test for exemption—reclassification by ordinance and approval by HLURB—was satisfied. The Court disregarded the DAR's findings that the land was irrigated or planted with rice, stating that once land is legally reclassified as non-agricultural, its physical topography or actual agricultural use becomes immaterial. Furthermore, the Court gave greater weight to the certification of the Deputized Zoning Administrator of Calapan City over the DAR's ocular reports, as the Zoning Administrator possesses specialized expertise and jurisdiction over land classification in the locality.
Main Doctrine
Local government units possess the absolute authority to convert or reclassify lands from agricultural to non-agricultural prior to the effectivity of Republic Act No. 6657 (CARL), provided that the reclassification was made through an ordinance approved by the Housing and Land Use Regulatory Board (HLURB) or its predecessor agency before June 15, 1988. Such reclassified lands are considered non-agricultural and thus outside the coverage of CARP.