Salas v. Cabungcal
NEW DOCTRINEFacts
The Antecedents: Augusto Salas, Jr. owned a vast tract of agricultural land in Lipa City, Batangas. Respondents were tenant farmers and agrarian reform beneficiaries on this land. The land was reclassified as a farmlot subdivision through a Town Plan/Zoning Ordinance of Lipa City approved by the Human Settlements Regulatory Commission (predecessor of HLURB) on December 2, 1981. Salas entered into an agreement for the development and sale of his land, and a Development Permit for a Nature Farmlots subdivision was issued on November 17, 1987. Salas subdivided the land, and Transfer Certificates of Title were issued in his name. Republic Act No. 6657 (CARP) was enacted on June 10, 1988, expanding agrarian reform coverage. Salas went missing in June 1989 and was later declared presumptively dead, with his wife appointed administrator of his estate. The Estate of Salas filed applications for exemption from CARP coverage, arguing the land was reclassified as non-agricultural prior to RA 6657's effectivity. These applications were initially granted by the DAR Secretary but later set aside upon motion for reconsideration. The Office of the President reinstated the exemption, but the Court of Appeals reversed this, reinstating the DAR's order denying exemption. Procedural History: The Estate of Salas filed protests and applications for exemption from CARP coverage. The Department of Agrarian Reform (DAR) denied the protests and dismissed others for lack of jurisdiction. A Notice of Coverage was issued, and Certificates of Land Ownership Award (CLOA) were distributed to farmer-beneficiaries. The DAR Secretary initially granted the exemption application for 17 lots on January 7, 2004. Upon motion for reconsideration by the farmer-beneficiaries, this order was set aside on September 19, 2006. The Office of the President reinstated the January 7, 2004 order. The Court of Appeals reversed the Office of the President, reinstating the DAR's September 19, 2006 order, which denied the exemption. The Petition: Petitioners (Heirs of Salas) filed a Petition for Review on Certiorari with the Supreme Court, assailing the Court of Appeals' decision that denied their application for exemption from CARP coverage.
Issue(s)
Whether the reclassification of petitioners' agricultural land as a farmlot subdivision exempts the Estate of Salas from the coverage of the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657. Whether Republic Act No. 6657 covers lands classified into non-agricultural uses prior to its effectivity. Whether Salas' farmlot subdivision falls under an 'agricultural land' as defined by applicable laws. Whether the 17 lots are covered under the Comprehensive Agrarian Reform Program.
Ruling
The petition is denied. The Decision of the Court of Appeals Second Division is affirmed. The temporary restraining order is permanently lifted.
Ratio Decidendi
On the primary issue of exemption from CARP coverage due to reclassification as a farmlot subdivision: The Court held that the reclassification of Salas' landholding into a "farmlot subdivision" did not change its nature as agricultural land. The definition of a farmlot subdivision under HLURB Regulations indicates it is primarily intended for intensive agricultural activities, even if secondarily for housing. This primary agricultural purpose means it remains an agricultural land under Republic Act No. 6657. The Court emphasized that an executive regulation, such as the HLURB's definition, cannot override or modify the statutory definition of agricultural land provided by Republic Act No. 3844 and Republic Act No. 6657. Therefore, the reclassification did not exempt the land from CARP coverage. On whether Republic Act No. 6657 covers lands classified into non-agricultural uses prior to its effectivity: The Court reiterated the principle established in Natalia Realty Inc. v. Department of Agrarian Reform that lands not devoted to agricultural activity, including those previously converted to non-agricultural uses by government agencies other than the DAR prior to the effectivity of Republic Act No. 6657 (June 15, 1988), are outside CARP coverage. However, this principle applies only if the conversion was to uses like residential, commercial, or industrial. In this case, the reclassification was to a "farmlot subdivision," which the Court found to retain its agricultural character. On whether Salas' farmlot subdivision falls under an 'agricultural land' as defined by applicable laws: The Court defined agricultural land under Republic Act No. 6657 as land devoted to agricultural activity and not classified as mineral, forest, residential, commercial, or industrial land. The investigation report confirmed agricultural activities on the lots, and they were not classified as mineral or forest lands. Crucially, the reclassification as a "farmlot subdivision" by the Lipa City Town Plan/Zoning Ordinance, approved by HLURB's predecessor, was not a classification for residential, commercial, or industrial use. Therefore, the lots met the definition of agricultural land. On whether the 17 lots are covered under the Comprehensive Agrarian Reform Program: Based on the preceding points, the Court concluded that the 17 lots were indeed covered under CARP. The reclassification as a farmlot subdivision did not alter their fundamental agricultural nature. The Court also noted that the principle of tilting the balance in favor of the poor and underprivileged in cases of doubt applies, reinforcing the inclusion of these lands under the social legislation of CARP. The Court found that the HLURB's restrictive definition of agricultural land, which excluded farmlot subdivisions, was an invalid attempt to modify the law and was effectively repealed by Republic Act No. 6657.
Main Doctrine
A reclassification of agricultural land into a 'farmlot subdivision' does not remove it from the coverage of the Comprehensive Agrarian Reform Program (CARP) if the land remains devoted to or suitable for agricultural activity and has not been classified as mineral, forest, residential, commercial, or industrial land prior to June 15, 1988. The primary use for agricultural activities, even with a secondary allowance for housing, maintains its character as agricultural land under CARP.