Garcia v. Santos Ventura Hocorma Foundation, Inc.
REITERATIONFacts
The Antecedents: Respondent Santos Ventura Hocorma Foundation, Inc. (SVHFI) is the registered owner of a 25.5699-hectare land in Mabalacat, Pampanga. Petitioners, claiming to be farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP), were recipients of Certificates of Land Ownership Award (CLOA) for portions of this land. On September 20, 2002, the Municipal Agrarian Reform Office (MARO) sent a Notice of Coverage to SVHFI. SVHFI protested, alleging ownership, the land's susceptibility to lahar and flooding, the Land Bank of the Philippines' (LBP) refusal to accept the claim folder, and that CARP coverage was unconstitutional. The LBP issued a Memorandum of Valuation and a Certification of Deposit for compensation. Subsequently, CLOAs were registered and distributed to farmer-beneficiaries. However, it was discovered that SVHFI sold the land to the Bases Conversion Development Authority (BCDA) after the Notice of Coverage was issued, without DAR clearance. Procedural History: The DAR Regional Director denied SVHFI's protest, finding the land agricultural and within CARP coverage, and deeming the sale to BCDA as indicative of bad faith. SVHFI's motion for reconsideration, arguing the land was reclassified and is now an expressway, was denied. Despite an Order of Finality, SVHFI filed an application for exemption clearance. The DAR Secretary granted SVHFI's application, ruling the property was reclassified to non-agricultural purposes before June 15, 1988, and thus erroneously covered by CARP. The DAR Secretary denied SVHFI's motions for reconsideration and a subsequent manifestation. Petitioners appealed to the Office of the President (OP), which affirmed the DAR Secretary's decision. Petitioners then filed a petition for review with the Court of Appeals (CA), which also affirmed the OP and DAR Secretary's rulings, holding the CLOAs were erroneously issued. Petitioners filed a motion for reconsideration, which the CA denied. The Petition: Petitioners seek reversal of the CA's decision, arguing the subject property is exempt from CARP coverage and that they are entitled to ownership based on the CLOAs.
Issue(s)
Whether the subject property owned by respondent SVHFI is exempt from CARP coverage. Whether petitioners are entitled to be the owners of the subject property pursuant to the CLOAs previously issued to them, and procedural arguments raised by petitioners.
Ruling
The petition is denied. The Court affirmed the Court of Appeals' Decision and Resolution, upholding the exemption of the subject landholding from CARP coverage and consequently, the erroneous issuance of the CLOAs to the petitioners.
Ratio Decidendi
On the issue of exemption from CARP coverage: The Court reiterated that for a landholding to be exempt from CARP coverage, it must be classified as non-agricultural prior to June 15, 1988. Republic Act No. 6657 (CARL) defines agricultural land as land devoted to agricultural activity and not classified as mineral, forest, residential, commercial, or industrial land. Department of Justice (DOJ) Opinion No. 44, Series of 1990, clarifies that lands already classified as commercial, industrial, or residential before June 15, 1988, are outside CARP coverage, though an exemption clearance from the DAR is still required. The DAR Secretary has the authority to grant or deny such clearances. In this case, SVHFI presented several documents, including certifications from the Housing and Land Use Regulatory Board (HLURB) and the Municipal Planning and Development Office (MPDO), indicating that the subject property was zoned as Residential per an approved Comprehensive Land Use/Zoning Ordinance in 1980, and later reclassified as Commercial per a Municipal Ordinance in 2003. An ocular inspection also confirmed the development into the Subic-Clark-Tarlac Expressway. These pieces of evidence, considered by the DAR Secretary, the OP, and the CA, sufficiently established that the land was reclassified to non-agricultural uses before June 15, 1988. The Court emphasized that factual findings of administrative agencies like the DAR, which possess technical expertise, are generally accorded respect and finality, absent grave abuse of discretion or arbitrariness. The Court found no persuasive ground to disturb these findings. On the entitlement of petitioners to ownership based on CLOAs and procedural arguments: Corollary to the exemption of the land from CARP coverage, the Court held that the CLOAs issued to the petitioners were erroneously issued. Since the land was never covered by CARP from the beginning, the farmer-beneficiaries could not have derived any vested rights over the property, and the original owners (SVHFI) were never divested of their rights. The indefeasibility of CLOAs, as provided under Section 24 of RA 6657, as amended, applies after one year from registration, subject to conditions and limitations. However, in this case, the basis for the CLOAs was an erroneous coverage. The Court noted that while the DAR Secretary's Order, affirmed by the OP and CA, declared the CLOAs as erroneously issued and entitled affected beneficiaries to disturbance compensation, it did not explicitly cancel the specific TCTs. Therefore, a separate proceeding would still be necessary to formally cancel the CLOA titles of the farmer-beneficiaries, impleading them as indispensable parties. The petitioners' contentions regarding the finality of the DAR Regional Director's Order and the timeliness of SVHFI's application for exemption were deemed untenable. The Court reiterated that administrative agencies like the DAR are not bound by strict technical rules of procedure and evidence, as provided in Section 50 of RA 6657, and should employ all reasonable means to ascertain facts in accordance with justice and equity. The DAR Secretary's entertainment of the application, despite the prior finality of the Regional Director's order and the delay in filing, was not considered an error, especially since the petitioners had ample opportunity to be heard through motions for reconsideration and appeals, thus curing any alleged defects in due process. The Court also dismissed the petitioners' attempt to introduce new evidence (a certification dated September 18, 2006) for the first time on appeal, citing the rule that appellate courts generally do not consider evidence not presented in the lower proceedings and that only questions of law should be raised in petitions for review on certiorari.
Main Doctrine
A landholding already classified as non-agricultural prior to June 15, 1988, is exempt from CARP coverage, and the issuance of Certificates of Land Ownership Award (CLOAs) for such land is erroneous. The Department of Agrarian Reform (DAR) Secretary has the authority to grant exemption clearances, and factual findings of administrative agencies with technical expertise are accorded respect and finality.