Rom v. Roxas

G.R. No. 169331 (September 5, 2011)

Court upheld Roxas & Co.'s agrarian reform exemption, affirming DAR's authority despite procedural errors.

Facts:

The case involves a petition for review on certiorari filed by several petitioners against Roxas & Company, Inc. regarding the latter's application for exemption from the Comprehensive Agrarian Reform Program (CARP) coverage for 27 parcels of land in Barangay Aga, Nasugbu, Batangas. The total area of the land in question is approximately 21.1236 hectares, which was previously covered by Transfer Certificate of Title No. T-44664.

On September 30, 1997, Roxas & Company, Inc. submitted an application to the Department of Agrarian Reform (DAR) for exemption from CARP coverage, asserting that the land had been reclassified as part of a Residential Cluster Area prior to the enactment of the Comprehensive Agrarian Reform Law (CARL) on June 15, 1988. The application was supported by various certifications, including those from the Municipal Planning and Development Coordinator and the Housing and Land Use Regulatory Board, confirming the land's classification as residential.

The DAR initially required proof of disturbance compensation to the farmer-beneficiaries occupying the land, which led to a dispute over the compensation amount. After failing to reach an agreement, Roxas & Company filed a petition to fix the disturbance compensation before the Provincial Agrarian Reform Adjudication Board (PARAD) of Batangas.

On November 6, 2002, the DAR granted the application for exemption, subject to conditions that the farmer-occupants would maintain possession until compensation was determined and that no development would occur until compensation was paid. The petitioners, who were the farmer-beneficiaries, filed multiple motions for reconsideration, arguing that the DAR's decision was based on outdated certifications and that they had not been properly notified of the proceedings.

The DAR denied the motions for reconsideration, leading the petitioners to file a petition for certiorari with the Court of Appeals, which was subsequently dismissed. The petitioners then sought a review from the Supreme Court.

Legal Issues:

  1. Whether the Court of Appeals erred in affirming the DAR's grant of exemption from CARP coverage despite the petitioners' claims of lack of jurisdiction and failure to pay disturbance compensation.
  2. Whether the petitioners properly invoked certiorari as a remedy instead of a petition for review under Rule 43 of the Rules of Court.
  3. Whether the previous voluntary offer to sell the land to the DAR barred Roxas & Company from withdrawing the land from CARP coverage.

Arguments:

Petitioners' Arguments:

  • The DAR lacked jurisdiction to grant the exemption because the application was not accompanied by proof of disturbance compensation, which they argued was a prerequisite for jurisdiction.
  • They contended that the certifications relied upon by the DAR had been superseded by a later resolution classifying the area as agricultural.
  • The petitioners claimed that they had a vested right to the land due to the issuance of Certificates of Land Ownership Award (CLOAs) and that the application for exemption was barred by laches.
  • They argued that certiorari was the proper remedy because they were questioning the jurisdiction of the DAR.

Respondent's Arguments:

  • Roxas & Company contended that the petitioners had chosen the wrong mode of appeal, asserting that a petition for review under Rule 43 was the appropriate remedy.
  • They argued that the DAR had jurisdiction over the application and that the lack of disturbance compensation did not deprive the DAR of the power to act on the application.
  • The respondent maintained that the land had been reclassified as residential prior to the CARL's effectivity, thus exempting it from CARP coverage.
  • They also asserted that the previous voluntary offer to sell did not prevent them from applying for exemption since the land was no longer agricultural.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the decision of the Court of Appeals, affirming the DAR's grant of exemption. The Court ruled that the petitioners had indeed resorted to the wrong remedy by filing a petition for certiorari instead of a petition for review under Rule 43. The Court emphasized that the DAR had jurisdiction over applications for exemption and that errors in the exercise of that jurisdiction were merely errors of judgment, not grounds for certiorari.

The Court found that the DAR's decision was supported by substantial evidence, including certifications that established the land's classification as residential prior to the CARL's enactment. The Court also noted that the DAR's requirement for disturbance compensation was a condition of the exemption order, and the petitioners' fears of losing their land without compensation were unfounded since the order explicitly required compensation to be paid.

Furthermore, the Court clarified that the previous voluntary offer to sell did not bar Roxas & Company from seeking exemption, as the land was no longer subject to CARP coverage due to its reclassification.

Significant Legal Principles Established:

  • The jurisdiction of the DAR over applications for exemption from CARP coverage is conferred by law, and errors in its exercise are not grounds for certiorari.
  • The requirement for disturbance compensation is a condition of the exemption order but does not negate the DAR's jurisdiction to grant such exemptions.
  • A landowner's previous voluntary offer to sell does not preclude them from applying for exemption if the land is classified as non-agricultural.