Kasamaka-Canlubang, Inc. v. Laguna Estate Development Corporation
REITERATIONFacts
The Antecedents: Respondent Laguna Estate Development Corporation (LEDC) obtained an order from the Ministry of Agrarian Reform (now DAR) in 1979 for the conversion of 10 parcels of agricultural land (216.7394 hectares) in Laguna to residential land, subject to the condition that development must commence within two years. Procedural History: In 2004, petitioner KASAMAKA-Canlubang, Inc. filed a petition for revocation of the conversion order, alleging non-development. In 2006, the DAR Secretary partially revoked the conversion order for eight parcels, excluding two based on a DAR Exemption Order. LEDC moved for reconsideration, arguing the eight parcels were also outside CARL coverage due to municipal reclassification as non-agricultural. An ocular inspection revealed two of the eight parcels remained undeveloped, but the DAR Secretary affirmed the revocation of seven parcels. The Office of the President (OP) reversed the DAR Secretary's order, exempting the seven parcels from CARL coverage and reinstating the 1979 conversion order. The CA dismissed KASAMAKA-Canlubang's petition for review, and its motion for reconsideration was denied. Hence, the present petition. The Petition: Petitioner argues the CA erred in ruling that undeveloped areas could no longer be considered agricultural and that zoning ordinances did not ipso facto change the nature of existing agricultural lands or existing legal relationships.
Issue(s)
Whether the Court of Appeals erred in ruling that the undeveloped areas of the landholdings subject of the conversion order could no longer be considered agricultural lands. Whether the Court of Appeals erred in failing to consider that the conversion order and municipal zoning ordinances reclassifying the subject landholding to non-agricultural uses prior to Republic Act No. 6657 did not ipso facto change the nature of existing agricultural lands or the legal relationship then existing over such lands.
Ruling
The petition is denied. The Decision of the Court of Appeals, dated June 27, 2011, and its Resolution dated January 31, 2012, in CA-G.R. SP No. 110585, which affirmed the Decision of the Office of the President, dated March 23, 2009, are affirmed.
Ratio Decidendi
On the issue of whether undeveloped areas could no longer be considered agricultural lands: The Court affirmed the CA's ruling, emphasizing that findings of fact by the CA are generally conclusive and binding. The Court found that the DAR Secretary's revocation order was based on inconsistent findings compared to the ocular inspection report, which indicated that six out of eight parcels had been developed. Furthermore, the petitioner failed to present substantial evidence to prove non-compliance with the conversion order, such as the original site development plan and the level of completion. The Court noted that the Office of the President found satisfactory evidence of development, including existing road networks and improvements, and that subdivision development is often undertaken in phases. The Court reiterated that lands reclassified as non-agricultural before June 15, 1988, are outside CARL coverage, citing precedents like Natalia Realty, Inc. v. Department of Agrarian Reform and Pasong Bayabas Farmers Association, Inc. v. Court of Appeals. On the issue of whether zoning ordinances ipso facto changed the nature of agricultural lands and existing legal relationships: The Court distinguished the present case from Co v. Intermediate Appellate Court. Firstly, the Co case involved an agricultural tenancy arrangement, which was absent in the present case; petitioner failed to present evidence of a leasehold arrangement. The conversion order itself noted that the subject lands were unirrigated, untenanted, and not devoted to agricultural production. Secondly, the Co case did not involve an order of conversion that categorically declared the land as converted for residential use, unlike the present case where the respondent's application for conversion was granted. The Court applied the doctrine that lands reclassified for non-agricultural uses prior to June 15, 1988, are outside the ambit of CARL, citing Buklod ng Magbubukid sa Lupaing Ramos, Inc. v. E.M. Ramos and Sons, Inc. The Court found that municipal zoning ordinances issued in 1979 and 1980 effectively converted the subject lands to residential areas before the effectivity of CARL on June 15, 1988, thus excluding them from CARL coverage. The Court concluded that petitioner failed to sufficiently prove non-compliance with the conversion order and failed to refute the rule that lands already classified as non-agricultural before June 15, 1988, are outside CARL coverage.
Main Doctrine
Lands reclassified as non-agricultural by valid zoning ordinances prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL) on June 15, 1988, are outside the coverage of CARL, even if they were originally agricultural lands. The existence of an agricultural tenancy relationship is a crucial factor in determining the applicability of zoning ordinances to existing agricultural lands.