Santos Ventura Hocorma Foundation v. Manalang
REITERATIONFacts
The Antecedents: Petitioner Santos, Ventura, Hocorma Foundation, Inc. (SVHFI) is the registered owner of Lot No. 554-D-3. On September 20, 2002, the lot was placed under the coverage of the Comprehensive Agrarian Reform Program (CARP). Subsequently, Certificates of Land Ownership Award (CLOAs) were issued to respondents as farmer-beneficiaries. SVHFI later executed a Deed of Absolute Sale with the Bases Conversion Development Authority (BCDA) for portions of Lot No. 554-D-3 for the construction of the Subic-Clark-Tarlac Expressway (SCTEX). Procedural History: Respondents filed a petition to nullify the sale between SVHFI and BCDA, asserting their rights as farmer-beneficiaries. SVHFI, in turn, filed a petition for the cancellation of the CLOAs, claiming the property was reclassified as residential land in 1980, prior to RA 6657. The DAR Secretary granted SVHFI's application for exemption from CARP coverage, citing the land's reclassification. The DARAB initially ruled in favor of the respondents but later reversed its decision, granting SVHFI's motion for reconsideration and ordering the cancellation of the CLOAs. The Office of the President affirmed the DAR Secretary's findings. The Court of Appeals (CA) reversed the DARAB's resolution, reinstating the DARAB's original decision that favored the respondents. SVHFI then filed the present petition for review on certiorari. The Petition: SVHFI assails the CA's decision, arguing that Lot No. 554-D-3 is exempt from CARP coverage due to its prior reclassification as non-agricultural land. The core issue is whether the CA erred in reversing the DARAB's resolution that declared the lot exempt from CARP coverage.
Issue(s)
Whether Lot No. 554-D-3 is covered by the CARP pursuant to RA No. 6657. Whether the Court of Appeals erred in reversing the Resolution of the DARAB which declared Lot No. 554-D-3 exempt from coverage and consequently ordered the cancellation of the CLOAs issued to respondents; including the vested rights of farmer-beneficiaries, the reclassification of land, and the application of Natalia Realty, Inc. v. Department of Agriculture.
Ruling
The Supreme Court grants the petition, reverses and sets aside the assailed Decision and Resolution of the Court of Appeals, and reinstates the Resolution of the Department of Agrarian Reform Adjudication Board dated December 16, 2011, which declared Lot No. 554-D-3 exempt from the coverage of the Comprehensive Agrarian Reform Program and ordered the cancellation of the Certificates of Land Ownership Award issued in the name of respondents.
Ratio Decidendi
On the coverage of Lot No. 554-D-3 under CARP: The Court held that Lot No. 554-D-3 is exempt from CARP coverage. This is primarily based on the finding that the land was reclassified as non-agricultural (residential) by the local government of Mabalacat, Pampanga, through its Comprehensive Land Use Plan/Zoning Ordinance, and ratified by the Human Settlements Regulatory Commission (HSRC, now HLURB) in Resolution No. R-41-3, Series of 1980, dated December 4, 1980. This reclassification occurred prior to the effectivity of RA No. 6657 on June 15, 1988. According to DOJ Opinion No. 44 and DAR Administrative Order No. 6, Series of 1994, lands already classified as non-agricultural before June 15, 1988, no longer need conversion clearance and are exempt from CARP coverage. The Court emphasized that the DAR Secretary's authority to approve conversions applies only to conversions made on or after June 15, 1988. The ocular inspection also revealed that significant portions of the land were already developed into the SCTEX, further indicating its non-agricultural use. On the Court of Appeals' alleged error, vested rights, reclassification, and application of Natalia Realty: The Court affirmed that the DAR Secretary has exclusive jurisdiction over matters involving the administrative implementation of RA No. 6657, including classification and identification of landholdings for CARP coverage and applications for exemptions. The DARAB, in its resolution, did not encroach upon the DAR Secretary's authority but merely adopted his findings regarding the exemption of Lot No. 554-D-3. The Court clarified that the CA erred in its assessment of the DAR Secretary's orders, mistaking a revocation order for a different lot (Lot 530) as applicable to Lot No. 554-D-3. The exemption orders for Lot No. 554-D-3 remained valid and were affirmed by the Office of the President. The Court found that respondents could not have derived any vested rights over Lot No. 554-D-3 despite the issuance of CLOAs in their favor in 2005 because the land had already been reclassified as non-agricultural in 1980, long before the CLOAs were issued and even before the enactment of RA No. 6657. The Court relied on the HLURB Certification and MPDO Certification, which indicated that Lot No. 554-D-3 was zoned for residential use per the approved Comprehensive Land Use/Zoning Ordinance of Mabalacat, Pampanga, ratified by HSRC Resolution No. R-41-3 dated December 4, 1980. The Court applied the principle established in Natalia Realty, Inc. v. Department of Agriculture, which held that undeveloped portions of a subdivision intended for residential use, reclassified by competent authorities prior to June 15, 1988, cease to be agricultural lands and are exempt from CARP coverage.
Main Doctrine
Lands already classified as non-agricultural before June 15, 1988, are exempt from CARP coverage and do not require conversion clearance, as the DAR's authority to approve conversions applies only from the effectivity date of RA 6657. The reclassification of land to non-agricultural purposes prior to the issuance of CLOAs means no vested rights accrued to farmer-beneficiaries.