Heirs of Gonzales v. De Leon
REITERATIONFacts
The Antecedents: The core dispute concerns approximately 49.8 hectares of land in Cabuyao, Laguna, registered under the name of Pacifico Gonzales. The Department of Agrarian Reform (DAR) issued Notices of Coverage for these properties under the Comprehensive Agrarian Reform Program (CARP) in 1995 and 2000. However, the Department of Environmental and Natural Resources (DENR) issued an Inspection Report in 2001, declaring the land exempt from CARP due to its steep slope (over 18%), lack of irrigation, uncultivated areas, and non-cultivation with rice and corn. Furthermore, the Municipal Planning and Development Coordinator (MPDC) of Cabuyao certified in 2002 that the properties were zoned as a municipal park based on a 1979 municipal ordinance approved by the Housing and Land Use Regulatory Board (HLURB) in 1980, predating the CARP notices. A Municipal Agrarian Reform Office (MARO) certification in 2002 also stated the properties were not covered by Operation Land Transfer. Procedural History: In 2002, the heirs of Pacifico Gonzales filed an ejectment case against respondents, who claimed to be tenants. The Municipal Trial Court (MTC) ruled in favor of the heirs, finding no tenancy relationship and ordering the respondents to vacate. This decision was affirmed by the Regional Trial Court (RTC). The respondents appealed to the Court of Appeals (CA) via a Petition for Review, which was also denied. Subsequently, the respondents' petition to the Supreme Court was denied. Concurrently, the heirs applied for exemption from CARP coverage. The DAR initially approved the exemption in 2006, lifting the Notices of Coverage. However, upon reconsideration in 2007, the DAR revoked its earlier order, upholding the Notices of Coverage, citing a Supreme Court decision that allegedly found lands in the area to remain agricultural. The heirs appealed this DAR order to the Office of the President (OP), which affirmed the DAR's decision in 2011. The heirs then appealed to the CA, which affirmed the OP's ruling in 2013, concluding the land was agricultural and thus covered by CARP. The Petition: The Heirs of Pacifico Gonzales, represented by Roger Banzuela, seek review of the CA's decision through a Petition for Review on Certiorari. They argue that the subject properties are not agricultural, citing the DENR's findings of steep slopes, lack of irrigation, and uncultivated areas, as well as the prior classification as a municipal park by local ordinance approved by the HLURB. They contend that these factors exempt the land from CARP coverage under Section 10 of R.A. No. 6657. Petitioners also challenge the OP's reliance on an alleged DENR certification dated January 5, 2005, which they claim was never presented. Furthermore, they assert that the respondents failed to prove the existence of a tenancy relationship, a prerequisite for CARP beneficiaries, pointing to the final and executory decisions in the ejectment case that explicitly found no such relationship. They argue that the CA erred in disregarding the established zoning classification and the findings of the ejectment case, and in failing to consider that vested rights must accrue prior to land reclassification for CARP coverage to apply.
Issue(s)
Whether or not the subject properties are agricultural and therefore covered by the Comprehensive Agrarian Reform Program (CARP). Whether or not there is a tenancy relationship between the petitioners and the respondents which would entitle the latter as "qualified beneficiaries" relative to the Department of Agrarian Reform's inclusion of the subject properties under the coverage of the Comprehensive Agrarian Reform Program.
Ruling
The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Decision of the Court of Appeals, the Decision of the Office of the President, and the Order of the Department of Agrarian Reform dated June 19, 2007. The Court REINSTATED the September 19, 2006 Order of the Department of Agrarian Reform, which granted the exemption and lifted the Notices of Coverage.
Ratio Decidendi
On the issue of whether the subject properties are agricultural: The Supreme Court ruled that the subject properties are not agricultural lands and are therefore outside the coverage of the Comprehensive Agrarian Reform Program (CARP). The Court emphasized that for land to be considered outside CARP coverage based on zoning, two conditions must concur: (1) the land must have been classified in town plans and zoning ordinances as residential, commercial, or industrial; and (2) the town plan and zoning ordinance must have been approved by the HLURB or its predecessor agency prior to June 15, 1988. In this case, Municipal Ordinance No. 110-54, Series of 1979, classified the subject property as a municipal park, and this ordinance was approved by the HLURB on June 25, 1980, satisfying both conditions. The Court found that the DENR's findings regarding the land's slope (over 18%), lack of irrigation, and uncultivated areas further supported its non-agricultural nature, aligning with Section 10 of R.A. No. 6657 which exempts lands with an 18% slope and over from CARP coverage. The Court also noted that the respondents failed to present evidence of any vested rights as farmer-beneficiaries prior to the land's reclassification as a municipal park, distinguishing it from cases where such rights had already accrued. On the issue of whether there is a tenancy relationship: The Supreme Court held that the respondents failed to establish the existence of a tenancy relationship with the petitioners. This finding was based on the prior ejectment suit where the MTC, RTC, and CA all concluded that no tenancy relationship existed. The Court reiterated that the essential requisites for tenancy, such as consent of the landowner, personal cultivation, and sharing of harvests, were not sufficiently proven by the respondents. The mere presence of some cultivation or backyard hog raising did not automatically establish them as farmworkers or tillers with vested rights under CARP. The Court emphasized that the burden of proof rests on the claimant to establish tenancy, and the respondents failed to discharge this burden. Consequently, without a proven tenancy relationship, the respondents could not be considered qualified beneficiaries under Section 22 of R.A. No. 6657.
Main Doctrine
Lands classified as municipal park by a municipal ordinance, approved by the HLURB prior to June 15, 1988, are outside the coverage of the Comprehensive Agrarian Reform Program (CARP), even if they were agricultural at the time of classification, provided no vested rights as farmer-beneficiaries had accrued prior to such reclassification.