TL;DR
The Supreme Court ruled that land exclusively dedicated to livestock raising since before June 15, 1988, is exempt from the Comprehensive Agrarian Reform Program (CARP). This decision protects long-standing livestock farms from being reclassified as agricultural land subject to redistribution. The court emphasized that livestock farms are considered industrial, not agricultural, and therefore fall outside the scope of agrarian reform, safeguarding the property rights of established livestock producers.
Pasture or Plough: When Does Land Reform Reach the Farm Gate?
This case, Heirs of Ramon Arce, Sr. v. Department of Agrarian Reform, centers on whether a 76.39-hectare property in Montalban, Rizal, used for livestock raising since the 1950s, should be covered by the Comprehensive Agrarian Reform Program (CARP). The Heirs of Ramon Arce, Sr. argued that their land was used for pasture and feed production for their livestock, making it exempt from CARP. The Department of Agrarian Reform (DAR), however, sought to include the land under CARP, leading to a legal battle that ultimately reached the Supreme Court, forcing a determination of whether the land was agricultural and subject to redistribution, or industrial and exempt.
The Comprehensive Agrarian Reform Program (CARP), enacted through Republic Act No. 6657, aims to redistribute agricultural land to landless farmers. However, the law explicitly excludes lands classified as mineral, forest, residential, commercial, or industrial. Section 3(c) of RA 6657 defines “agricultural land” as land devoted to agricultural activity. The pivotal question here is whether livestock raising qualifies as an “agricultural activity” under CARP.
The Supreme Court, in line with established jurisprudence, particularly the landmark case of Luz Farms v. The Honorable Secretary of the Department of Agrarian Reform, reiterated that livestock farms are not covered by CARP. That case declared provisions of the CARL unconstitutional when they included lands devoted to livestock. The Constitutional Commission of 1986 never intended to include livestock in the agrarian reform program, classifying it as industrial rather than agricultural activity.
it was never the intention of the framers of the Constitution to include the livestock and poultry industry in the coverage of the constitutionally mandated agrarian reform program of the government.
The Court examined the factual findings of the DAR, the Office of the President (OP), and the Court of Appeals (CA), noting inconsistencies that warranted a deeper look into the evidence. The DAR initially denied the Heirs’ petition for exclusion from CARP coverage, citing an ocular inspection report indicating the absence of livestock on the property. The OP, however, reversed this decision, finding that the land was indeed used for livestock raising. The Court of Appeals sided with the DAR, prompting the Heirs to elevate the case to the Supreme Court. Because of these conflicting opinions, the SC had to step in to provide guidance.
A critical aspect of the case was the transfer of some of the Arce’s livestock to a facility in Novaliches, Quezon City, due to a liver fluke infestation. The DAR argued that this transfer demonstrated that the land was no longer used for livestock purposes. However, the Supreme Court sided with the Arce Heirs, underscoring that the transfer was temporary and for health reasons, as recommended by the Philippine Carabao Center-Department of Agriculture (PCC-DA). The court emphasized that the younger livestock remained on the property, and the land continued to be used for growing napier grass to feed the livestock. The Heirs of Arce were able to provide ample proof of this.
The Court emphasized the importance of the Municipal Agrarian Reform Officer’s (MARO) findings, which supported the Heirs’ claim that the land was used for livestock farming. The MARO’s ocular inspection found large cattle on the property, and the DAR Provincial Office (DARPO) also recommended granting the petition for exclusion from CARP coverage. The Court found the MARO’s report to be much more compelling than that of Ucag of DAR Region IV-A, whose assessment was done without notifying the Heirs.
The Supreme Court also addressed the issue of SAMANACA’s attempt to intervene in the case. The Court denied their motion, stating that SAMANACA’s members had never been in possession of the subject lands or been tenants, farmers, or tillers. SAMANACA did not provide compelling evidence they were qualified beneficiaries. This lack of a direct and immediate legal interest in the outcome of the case disqualified them from intervening.
The Court highlighted that the feedlot operation adopted by the petitioners, where animals are confined and fed on a cut-and-carry basis, is a recognized method of livestock raising. The land’s use for growing napier grass to feed the livestock further supported the argument that it was dedicated to livestock production, not agriculture in the traditional sense. Additionally, the Court pointed out that the land’s topography, with slopes exceeding 18%, made it unsuitable for traditional agriculture, further solidifying its classification as non-agricultural.
The Supreme Court concluded that the land had been exclusively devoted to livestock raising since before the enactment of CARP. Therefore, it was exempt from agrarian reform. The decision underscores the importance of preserving the original intent of the Constitution to exclude livestock farms from agrarian reform and protecting established industries from land redistribution.
FAQs
| What was the key issue in this case? | Whether land used for livestock raising since before the enactment of the Comprehensive Agrarian Reform Program (CARP) should be covered by CARP and redistributed to landless farmers. |
| What did the Supreme Court decide? | The Supreme Court ruled that the land was exempt from CARP because it was dedicated to livestock raising, which is considered an industrial activity, not agriculture, and therefore outside the scope of agrarian reform. |
| Why was the land initially placed under CARP coverage? | The Department of Agrarian Reform (DAR) initially placed the land under CARP coverage based on an ocular inspection report that claimed there were no livestock on the property. |
| What evidence did the Heirs of Ramon Arce, Sr. present to support their claim? | The Heirs presented certificates of ownership of large cattle, photos of livestock grazing on the property, and reports from the Municipal Agrarian Reform Officer (MARO) and DAR Provincial Office (DARPO) confirming the land’s use for livestock raising. |
| What is a “feedlot operation” and why was it important in this case? | A “feedlot operation” is a method of livestock raising where animals are confined and fed on a cut-and-carry basis. It was important because it demonstrated that the land was being used to support livestock production, even though the animals were not freely grazing on the entire property. |
| Why was SAMANACA’s attempt to intervene in the case denied? | SAMANACA’s attempt to intervene was denied because its members had never been in possession of the land or been tenants, farmers, or tillers, and they failed to provide sufficient evidence that they were qualified beneficiaries. |
| What is the significance of the date June 15, 1988, in this case? | June 15, 1988, is the date the Comprehensive Agrarian Reform Law (CARL) took effect. The Court considered whether the land was used for livestock raising prior to this date in determining whether it qualified for an exemption. |
This decision reinforces the principle that lands genuinely and continuously dedicated to livestock raising before the enactment of CARP are protected from agrarian reform. This provides security to established livestock farmers and clarifies the boundaries of agrarian reform in the Philippines.
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: Heirs of Ramon Arce, Sr. v. Department of Agrarian Reform, G.R. No. 228503, July 25, 2018
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