Holy Trinity Realty v. Dela Cruz
REITERATIONFacts
The Antecedents: The case involves a parcel of land in Malolos, Bulacan, registered in the name of Freddie Santiago. Previous tenants voluntarily relinquished their tenancy rights in exchange for financial assistance and homelots. Petitioner Holy Trinity Realty and Development Corporation (Holy Trinity) purchased the remaining land from Santiago and developed it into a residential subdivision. The Sangguniang Bayan ng Malolos passed Municipal Resolution No. 16-98 reclassifying four lots as residential. Subsequently, the DAR Provincial Office filed a petition to annul the sale and requested the placement of the land under Operation Land Transfer (OLT) pursuant to Presidential Decree No. 27. The DAR Regional Director ordered the placement of the land under PD 27/RA 6657 and directed the issuance of Emancipation Patents (EPs) to the respondents. The DAR Secretary denied Holy Trinity's appeal, and the Office of the President (OP) reversed the DAR Secretary's ruling, finding the land reclassified as residential and not suitable for agriculture. The Court of Appeals (CA) reversed the OP's decision, holding the land to be agricultural and the reclassification invalid due to the use of a resolution instead of an ordinance. Procedural History: The DAR Regional Director ordered the placement of the land under PD 27/RA 6657 and the issuance of EPs. Holy Trinity's motion to quash was denied. The DAR Secretary denied Holy Trinity's appeal. The Office of the President reversed the DAR Secretary's order. The Court of Appeals reversed the OP's decision. Holy Trinity filed the present petition for review on certiorari. The Petition: Holy Trinity argues that the CA erred in failing to rule on several interrelated issues, including the legitimacy of the respondents as tenants, the validity of the sale and transfer of titles, the voluntary relinquishment of tenancy rights, and the property's non-agricultural status. It also contends that the CA erred in not ruling on the illegality of the DAR's summary coverage, the extra-judicial cancellation of titles without due process, and the premature issuance of EPs. Finally, it argues that the CA erred in applying RA 6657 when the DAR order was based on PD 27, and that the respondents' petition for review should have been dismissed for non-compliance with procedural rules.
Issue(s)
Whether the Court of Appeals erroneously omitted to rule upon various interrelated issues proffered in petitioner’s comment relative to DAR’s inclusion of the subject Dakila property under the coverage of the Agrarian Reform Law; and whether the Court of Appeals erred in failing to rule on the illegality of the manner by which the DAR caused the summary coverage of the Dakila property under the CARP, its extra-judicial cancellation of petitioner’s titles without due process of law, and its premature issuance of Emancipation Patents in favor of respondents. Whether the Court of Appeals erroneously applied the provisions of RA 6657 in resolving the subject petition, even though the DAR placed the subject Dakila property under the coverage of Presidential Decree No. 27; specifically, whether the Dakila Property Was Agricultural Land within the Coverage of RA 6657 or PD 27. Whether herein respondents’ petition for review ought to have been dismissed outright by the Honorable Court of Appeals for failure to comply with Section 4, Rule 7 of the 1997 Revised Rules of Civil Procedure; specifically, on the procedural issue of verification. On the Courts' Authority to Pass Upon Matters Related to Issues Raised; and whether the issuance of EPs was proper.
Ruling
The Court GRANTS the petition for review on certiorari; REVERSES and SETS ASIDE the decision promulgated on July 27, 2011 by the Court of Appeals; REINSTATES the assailed decision of the Office of the President issued on March 1, 2010; DIRECTS the cancellation of Emancipation Patents No. 00783329, No. 00783330, No. 0078331, No. 0078332, No. 0078333, and No. 0078334 issued to the respondents for being NULL and VOID; and ORDERS the respondents to pay the costs of suit.
Ratio Decidendi
On the Issues of DAR's Inclusion of the Dakila Property and Illegality of DAR's Actions: The Court affirmed that appellate courts are vested with sufficient authority to review matters not assigned as errors on appeal if their consideration is necessary for a just and complete resolution of the case. The CA could have reviewed unassigned errors closely related to assigned errors or upon which the determination of assigned errors was dependent. The validity of the EPs was intertwined with the issue of whether the Dakila property was covered by agrarian reform laws, and the CA's limited ruling left unresolved questions. On Whether the Dakila Property Was Agricultural Land within the Coverage of RA 6657 or PD 27: The Court found that while the CA correctly noted that an ordinance, not a resolution, is required for land reclassification under RA 7160, it erred in concluding that the Dakila property was agricultural land subject to coverage. The primary condition for coverage under RA 6657 is that the land must be devoted to or suitable for agriculture. No evidence was presented to show that agricultural activity was being performed on the Dakila property. The previous tenants themselves surrendered their rights, citing the land's unsuitability for farming. Municipal Resolution No. 16-98 also stated the property was not fit for agricultural use due to lack of irrigation and was more suitable for residential use. Therefore, the Dakila property was not an agricultural land subject to coverage under RA 6657 or PD 27. The DAR Regional Office erred in subjecting it to OLT. On the Procedural Issue of Verification: The Court held that the verification of a petition is a formal, not a jurisdictional, requisite. Its non-compliance does not render the pleading defective, and courts may order its correction or act on an unverified pleading if it serves the ends of justice. The CA rightly allowed the petition for review despite the statement that allegations were based on "knowledge and belief," especially since the respondents later submitted a corrected verification. Furthermore, the respondents, as identified beneficiaries, had legal standing to intervene and sign the verification, as they became the real parties in interest upon the issuance of the EPs. On the Courts' Authority to Pass Upon Matters Related to Issues Raised and the Propriety of Issuing Emancipation Patents: The Court ruled that the issuance of EPs was improper. The DAR failed to follow the required procedures under RA 6657 and PD 27, including sending proper notices to the landowner and conducting public hearings. The petitioner was deprived of due process. There was no evidence of payment prior to the cancellation of Holy Trinity's titles, which is a condition for the award of an EP. The respondents also failed to establish their status as de jure tenants, as required for coverage under land reform laws. The allocation of lots to respondents also appeared suspect, with some exceeding the three-hectare limit for beneficiaries.
Main Doctrine
Land on which no agricultural activity is being conducted is not subject to the coverage of either Presidential Decree No. 27 or Republic Act No. 6657 (Comprehensive Agrarian Reform Law). Furthermore, the reclassification of agricultural land to non-agricultural use requires an ordinance, not merely a resolution, and must be preceded by public hearings. Failure to observe these procedural requirements constitutes a denial of due process.