TL;DR
The Supreme Court ruled that a Department of Agrarian Reform (DAR) exemption order must be final and executory before it can be used to cancel Certificates of Land Ownership Award (CLOAs) granted to farmer-beneficiaries. In this case, the exemption order for Almeda Incorporated’s land, reclassifying it as industrial before the Comprehensive Agrarian Reform Program (CARP), was not considered final because the farmer’s heirs filed a timely motion for reconsideration. The Court emphasized that until all appeals are exhausted, such orders cannot automatically nullify farmers’ rights to land awarded under agrarian reform. This decision protects farmer-beneficiaries from premature CLOA cancellations based on exemption orders still under legal challenge, ensuring their land rights are secure until due process is fully observed.
Tilling Rights Trump Zoning Plans: When Industrial Dreams Defer to Agrarian Justice
This case, Heirs of the Late Domingo Barraquio v. Almeda Incorporated, revolves around a dispute over land in Laguna, Philippines, initially awarded to farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP) through Certificates of Land Ownership Award (CLOAs). Almeda Incorporated, the landowner, sought to cancel these CLOAs, arguing that their property was exempt from CARP coverage because it had been reclassified as industrial land prior to the enactment of Republic Act No. 6657, the CARP law. The legal crux of the matter lies in determining whether a non-final exemption order from the Department of Agrarian Reform (DAR) can serve as a valid basis for nullifying CLOAs already issued to farmers.
The narrative began in 1994 when the DAR issued CLOAs to nine farmer-beneficiaries, including Domingo Barraquio, over land owned by Almeda Incorporated. Almeda contested this, claiming the land was already industrial and the farmer-beneficiaries were disqualified. Initially, the Provincial Agrarian Reform and Adjudication Board (PARAB) dismissed Almeda’s complaint, but later reversed its decision, ordering the CLOAs cancelled based on a 1989 municipal zoning ordinance reclassifying the land as industrial. This reversal hinged on the argument that land reclassified before June 15, 1988, the effectivity of Republic Act No. 6657, was exempt from CARP coverage, citing Department of Justice Opinion No. 44 and DAR Administrative Order No. 6.
However, the Supreme Court highlighted a critical procedural point: the finality of the exemption order. Justice Leonen, writing for the Second Division, stated, “An exemption order issued by the agrarian reform secretary must be final and executory before it may be used as basis to revoke or cancel certificates of land ownership award (CLOAs) issued to farmer-beneficiaries.” The Court found that Barraquio’s heirs had filed a motion for reconsideration against the DAR Secretary’s Exemption Order, and before this motion was resolved, a Certificate of Finality was prematurely issued. This premature finality was deemed legally infirm, preventing the Exemption Order from becoming a valid basis for CLOA cancellation.
The Court underscored the social justice objectives of agrarian reform, rooted in the Constitution’s mandate to empower landless farmers. Referencing the historical context of agrarian reform in the Philippines, from the encomienda system to post-colonial land reform efforts, the decision emphasized the comprehensive nature of Republic Act No. 6657. This law aims to justly distribute agricultural lands, covering “all public and private lands classified as agricultural,” as stated in Section 4. While acknowledging the power of local government units to reclassify land prior to Republic Act No. 6657, the Court reiterated that after its enactment, the DAR’s approval is required for land conversion. However, DOJ Opinion No. 44 clarified that lands already classified as non-agricultural before June 15, 1988, could be exempted from CARP, requiring an exemption order from the DAR Secretary.
The Supreme Court addressed procedural missteps, noting that while the Heirs of Barraquio technically availed of the wrong remedy in G.R. No. 185594 by filing a Petition for Certiorari instead of a Petition for Review, the Court relaxed procedural rules in the interest of substantial justice, particularly in social legislation cases. The Court also dismissed Almeda’s forum shopping claim, clarifying that G.R. No. 169649 (CLOA cancellation) and G.R. No. 185594 (Exemption Order validity) involved distinct issues, although related to the same property. The Court admitted newly discovered evidence presented by the petitioners – certifications from HLURB and the Zoning Administration indicating the land was agricultural – further bolstering their claim.
Ultimately, the Supreme Court sided with the Heirs of Barraquio, reversing the Court of Appeals’ decision and reinstating the CLOAs. The Court found inconsistencies in Almeda’s evidence and gave weight to the CLUPPI Secretariat’s evaluation report, which concluded that the properties were within an agricultural land use zone in the 1981 Zoning Ordinance. The Kautusang Bayan Blg. 237-’95 further indicated that the reclassification to industrial use occurred only in 1995, after Republic Act No. 6657 took effect. The ruling reinforces the principle that farmer-beneficiaries’ rights under agrarian reform are paramount and should not be easily overturned by exemption orders that have not yet attained finality, safeguarding the spirit and intent of CARP.
FAQs
| What is a Certificate of Land Ownership Award (CLOA)? | A CLOA is a land title issued to farmer-beneficiaries under the Comprehensive Agrarian Reform Program (CARP) in the Philippines, proving their ownership of the awarded land. |
| What is a DAR Exemption Order in the context of CARP? | A DAR Exemption Order is issued by the Department of Agrarian Reform, exempting certain lands from CARP coverage, typically because they were classified for non-agricultural use (like industrial) before CARP’s effectivity. |
| What was the main legal issue in this case? | The key issue was whether a non-final DAR Exemption Order could validly serve as the basis for cancelling CLOAs already issued to farmer-beneficiaries. |
| What did the Supreme Court rule in this case? | The Supreme Court ruled that a DAR Exemption Order must be final and executory before it can be used to cancel CLOAs. In this case, the Exemption Order was not final, thus the CLOA cancellation was reversed. |
| Why was the Exemption Order not considered final in this case? | Because the Heirs of Barraquio filed a timely motion for reconsideration against the Exemption Order, and a Certificate of Finality was issued prematurely before the motion was resolved. |
| What is the practical implication of this ruling? | This ruling protects farmer-beneficiaries from having their CLOAs cancelled based on exemption orders that are still being legally challenged, ensuring their land rights are secure until due process is complete. |
For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: THE HEIRS OF THE LATE DOMINGO BARRAQUIO, NAMELY GLENN M. BARRAQUIO, MARIA M. BARRAQUIO, GREGORIO BARRAQUIO, DIVINA B. ONESA, URSULA B. REFORMADO, AND EDITHA BARRAQUIO, PETITIONERS, VS. ALMEDA INCORPORATED, RESPONDENT. [G.R. No. 169649, January 16, 2023]
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