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GR NO. 178895, JANURAY 10, 2011

FACTS: Subject to this case were four lands registered under the name of the respondent covered by TCT
No. T-12635 (Lot 1454-A and 1296 also known as the Limut lands), TCT No. T-12637 (Lot 1298) and TCT
No. T- 12639 (Lot 1293-B). On August 2, 1991, the Municipal Agrarian Reform Officer (MARO) issued a
Notice of Coverage of the said lands under RA No. 6657 or CARL. Respondent then filed with the Provincial
Agrarian Reform Office (PARO) an application for the exemption of lots 1298 and 1293-B pursuant to the
ruling in Luz Farms case as these lots were used, prior to the enactment of CARL, as grazing and habitat
for the respondents’ livestock. The MARO investigated and concluded that these lots were indeed used as
a livestock grazing and should be exempted from CARL. Even with the presence of the coconut trees, the
financial statement showed that they only give 20% of the annual income compared to the 80% coming
from the livestock of the respondent. The titles on the Limut lands, however, were cancelled and put under
the name of the petitioner. Respondent filed a letter-affidavit asking for the exemption of these lands as
they were additional area for its livestock business. That DAR Regional Director, upon inspection, denied
the application on the grounds that it was clearly not shown that the lands were actually, directly, and
exclusively used for livestock but the other two lands were approved for exemptions. Respondent went on
to appeal before the CA, after its Motion for Reconsideration before the DAR Regional Director was denied,
and the latter approved the application for the exemption of the lots 1298 and 1293-B but denied such
exemption to the Limut lands. Hence this appeal.

ISSUE: Whether or not the Limot lands are considered grazing lands for livestock and should be exempted
from the coverage of CARL.

HELD: The Court held in the NEGATIVE. Although lots Nos. 1298 and 1293-B were considered as lands
for grazing livestock and therefore exempted in the coverage of CARL, the Limot lands are not of the same
character. As decided by the Court, they are agricultural lands and therefore covered by the CARL. As
stated in the Luz Farms case, lands devoted to livestock, poultry and swine are considered as industrial
lands and not agricultural. Thus, they are exempted from the agrarian reform. In the case of the Limot lands,
however, they were not actually and exclusively used as a grazing for livestock. The MARO, in its
investigation, found that the livestock were moved sporadically only on the lands. This was bolstered by the
fact that respondent only filed its application later and considered the lands as merely “additional lands for
GR NO. 180013, JANUARY 31, 2011

FACTS: The petitioners, an agrarian cooperative and a valid beneficiary of the CARP, were awarded an
entire landholding (1, 861, 922 m2) located in Sankanan, Manolo Fortich, Bukidnon covered by the Original
Certificate of Title No. AO-3 through a Certificate of Land Ownership Award (CLOA). They subsequently
leased it to Del Monte Philippines Inc. On July 7, 1998, thye filed a complaint for Recovery of Possession
and Specific Performance with Damages before the DARAB against Sangunay and Labunos (respondents)
alleging that they illegally entered the portions of their property and utilized it for building their houses and
livelihood. The respondents, on the other hand, argued that they have been in open , public, adverse,
peaceful, actual, physical, and continuous possession of the portions of land as owners since 1986 and
1950 respectively. Sangunay argued that they were accrual deposits and Labunos received the land from
his father who purchased it from a certain Genis Valdenueza in 1950. The DARAB first decided in favor of
the petitioners holding that bare possession does not prove ownership. Respondents presented tax
declarations and Real Property Historical Ownership. In May 12, 2006, DARAB dismissed the case for lack
of jurisdiction. It stated that the issue at hand is of ownership and that such case should fall within the
jurisdiction of regular courts. The Ca denied the Motion for Reconsideration filed by the petitioners due to
technicalities. Hence, this petition.

ISSUE: Whether or not the case presented by the petitioners fall within the jurisdiction of DARAB.

HELD: The Court held on the NEGATIVE. Under Section 50 of RA 6657, the DARAB, as the DAR’s quasi-
judicial body, has he primary, exclusive and original jurisdiction of all agrarian dispute cases, controversies
and disputes, and all matters involving the implementation of CARL. “An agrarian dispute refers to any
controversy relating to tenurial arrangements, whether leasehold, tenancy, stewardship, or otherwise, over
lands devoted to agriculture, including disputes concerning farmworkers’ associations or representation of
persons in negotiating, fixing, maintaining, changing, or seeking to arrange terms or conditions of such
tenurial arrangements. It includes any controversy relating to compensation of lands acquired under this
Act and other terms and conditions of transfer of ownership from landowner to farmworkers, tenants, and
other agrarian reform beneficiaries, whether the disputants stand in the proximate relation of farm operator
and beneficiary, landowner and tenant, or lessor and lessee”. In this case, the main issue is the ejectment
of the respondents from the land of the petitioner. As the case is absent of any issue regarding the
implementation of CARP or any of its provisions, the petition is denied.
GR NO. 172230, FEBRUARY 2, 2011

FACTS: This case revolved around the applicable law in the determination of just compensation.
Respondents inherited the land in dispute from their mother. They soon learned that a portion of it was
covered by an Emancipation Patent secretly issued in the name of Alfrdo Carbonel without payment of just
compensation. The petitioners fixed the price of 132, 685.65 or approximately 12, 050.00 per hectare in
violation of the guidelines in RA No. 6657 or the Comprehensive Agrarian Reform Law. They asserted that
it should be 250, 000 per hectare and a total sum of 2, 930, 000.00 for the entire land covered. On the other
hand, the petitioners argued that the property had been placed under the Operation of Land Transfer
Program and thus, the provisions of PD No. 27and EO No 228 shall apply. The RTC determined that the
CARL shall be used for the determination of the amount. Their succeeding appeals have been denied.
Thus, this petition.

ISSUE: Whether or not the provisions of CARL should apply in the determination of the amount of just
compensation to be paid to the respondents.

HELD: The Court held in the affirmative. It has been held in previous cases that the provisions of CARL
shall determine the just compensation for acquiring such lands and that PD No. 27 and EO No. 227 shall
only be suppletory. Furthermore, it has been held in the case of Paris vs. Alfeche that the provisions of
CARL shall also apply on lands covered by PD No. 27 and EO No 228. The case of Lubrica vs Land Bank
of the Philippines held that “that it would be highly inequitable on the part of the landowners therein to
compute just compensation using the values at the time of taking in 1972, and not at the time of payment,
considering that the government and the farmer-beneficiaries have already benefited from the land although
ownership thereof has not yet been transferred in their names.
GR NO. 182332, FEBRUARY 23, 2011

FACTS: Pursuant to the case of Luz Farms vs Sutton, petitioner filed for the exemption of his lot from the
coverage of RA no 6657 (CARP) on the ground that the 316.0422-hectare property was devoted to raising
of livestock, poultry, and/or swine. Subsequently, petitioner re-documented his application under DAR A.
O. No. 9 which was enacted to set rules and regulations and govern the exclusion of the agricultural lands
devoted for livestock raising. Upon investigation of the LUCEC, it was decided that the entire lot was
exempted. However, the Southern Pinugay Farmers moved for the reconsideration of the Order but was
denied by then Director Dalugdug. When RA No 6657 was amended by RA No. 7881 on 1995, the then
Secretary of DAR exempted only 240.9776 hectares and considered the remaining 75.0646 hectares to be
part of CARP. The Secretary concluded that the Certificates of Ownership of Large Cattle registered prior
to June 15, 1998 or when Carl took effect, only represented 86 heads of cattle. Therefore, considering the
animal-land ratio, as well as the infrastructure-animal ratio, it resulted to 240.9776 hectares of lands to be
exempted. Petitioner then appealed before the Office of the President which decided in favor of the
petitioners at first but on account of reconsiderations filed by famer-groups reversed such decision and
reinstated the findings of the Secretary. Petitioners appealed before the CA. On April 29. 2005, the CA
decided in favor of the petitioner and ordered the exemption of the said lands. However, unbeknownst to
the court, 6 months prior to the decision of the CA, petitioners filed for the conversion of portions of his
property from agricultural to residential and golf courses which was approved by Secretary Villa under the
DAR Conversion Order No. CON-0410-0016. When the CA was made known of the developments on the
property, and the fact that MARO reported that such property was no longer use as livestock farm, it
amended its earlier decision and held that the remaining lots were subject to CARP. Petitioners filed for a
Motion for Reconsideration which was denied by the CA because even after the declaration of
unconstitutionality of DAR AO No. 9 in the Sutton case, the findings of the MARO and DAR could not be
disregarded. In the case of Sutton, the property remained as one devoted for livestock and poultry grazing
while the present case is wanting of such fact. Petitioner then filed this petitioner before the Court.

ISSUE: Whether or not the remaining lots are covered by the CARP.

HELD: The Court held in the affirmative. It declared the remaining 162.7373 hectares as covered by CARP.
The decision in Sutton could not be applied in this case as the lands therewith remained to be dedicated to
grazing of livestock and cattle while the ones in this case were developed to agricultural, residential, and
golf courses. Even when the petitioners admitted that they leased their land for livestock since 2001
because the occupants were harming the cattle evidences failed to prove exhaustively the alleged illegal
acts. Finally, the Court held that the DAR has competence and jurisdiction. Under Section 3, Rule II of the
2003 Department of Agrarian Reform Adjudication Board Rules of Procedure, cases over matter involving
the administrative implementation of RA No. 6654 and other agrarian laws are under the exclusive
prerogative of the Office of the Secretary of DAR. To succumb to petitioners contention that when a land is
declared exempt from the CARP because it is not agricultural as of the time the CARL took effect, the use
and disposition of that land is entirely and forever beyond DARs jurisdiction is dangerous, suggestive of
self-regulation. Precisely, it is the DAR Secretary who is vested with such jurisdiction and authority to
exempt and/or exclude a property from CARP coverage based on the factual circumstances of each case
and in accordance with law and applicable jurisprudence
G.R. NO. 181370, MARCH 9, 2011

FACTS: In 1989, the petitioners alleged that respondent asked for the petitioner to help her redeem the lot
in dispute, which was mortgaged by respondents’ mother, Christina Hugo, to Trinidad Barreto. After
redeeming the lot for 250.00 Php and a cavan of palay, respondent again sought the help of petitioner in
obtaining title for the land from her mother and acquiring title over it under her name. In exchange, she
promised to give half of the land in dispute to the petitioners. She executed two Sinumpaang Salaysay, one
stating that she is transferring the rights of one-half of the land and the other, committing herself to remove
the house constructed on the corresponding one-half portion of the lot attributed to petitioner. When
respondent acquired the Certificate of Land Ownership from the DAR under her name for the entire 240-
sq. m. parcel of land on 1990, petitioners filed before the RTC of Martines City, Cavite in 1995, the
cancellation of such CLOA and the issuance of another under their name corresponding to the one-half
land which was promised to be given to him. The RTC decided in favor of the petitioners but the CA reversed
the Decision and maintained the validity of the CLOA under the respondents’ name.

ISSUE: Whether or not petitioner is entitled the one-half portion of the land on the basis of the waiver of
rights embodied in the two Sinumpaang Salaysay.

HELD: The Court in the negative. Under the Section 27, of the CARL, lands acquired by beneficiaries shall
not be sold, transferred or conveyed except through hereditary succession, or to the government, or to the
LBP, or to other qualified beneficiaries for a period of 10 years. Under DAR A. O. No. 3, Series of 1990, the
qualifications for a beneficiary under CARL are: landless, Filipino citizen, Actual occupant/tiller who is at
least 15 years of age or head of the family at the time of filing application, and has the willingness, ability
and aptitude to cultivate and make the land productive. According to the Court, petitioner is not landless as
he had been awarded by the DAR with a homelot already, and that he was not tilling the land in dispute at
the time of the application. It is clear, therefore, that respondents cannot transfer any of their rights on the
land to petitioners who are not considered as a valid beneficiary as well. Furthermore, the land cannot be
transferred to anyone within a period of 10 years.
G.R. NO. 181566 AND 181570, MARCH 9, 2011

FACTS: Petitioner Davao Fruits owned a bamboo plantation which consisted of 10 parcels of land with a
total area of 101.4416 hectares located in the Province of Compostela Valley. They voluntarily offered such
lands to the government under CARL for 300,000 Php per hectare or 30,432,480 Php for the entire property.
The DAR and the respondent LBP, however, computed that the value of the property was 4,055,402.85 for
the entire area. The issue was then referred to the DARAB and it was found that only 92.0625 hectares
were planted with bamboo and the rest was brush land. The DARAB fixed the price of the bamboo area at
300,000 Php per hectare and the brush land at 17,154.30 Php per hectare. Both the LBP and the Davao
Fruits moved for reconsideration. On October 2002, the LBP filed before the RTC of Tagum, Davao del
Norte a petition for the fixing of just compensation. This was assailed by the petitioner contending that LBP
has ano authority to sue on behalf of the Republic of the Philippines. LBP moved for the dismissal of such
motion which was dismissed by the Trial Court (SAC) on the ground that the conflicting views of the LBP
and the DAR may frustrate the implementation of the CARP and may send a wrong message to the
beneficiaries. The CA, however, found no basis that the conflicting views of the LBP and the DAR may
frustrate the implementation of the agrarian reform and denied that the LBP had no personality to sue and
question the further valuation of the DARAB.

ISSUE: Whether or not LBP has the personality to file a petitioner for determination of just compensation
before the Court.

HELD: The Court held in the affirmative. According to the agrarian reform law, the LBP shall be the financial
intermediary for the CARP, and shall insure that the social justice objectives of the CARP shall enjoy a
preference among its priorities. Furthermore, in Heirs of Roque F. Tabuena v. Land Bank of the Philippines,
it was already held that the LBP may agree with DAR and the land owner as to the amount of just
compensation to be paid and it may disagree with them as well and bring the matter to court for judicial
determination. BP is an agency created primarily to provide financial support in all phases of agrarian reform
pursuant to Section 74 of Republic Act (RA) No. 3844 and Section 64 of RA No. 6657. It is vested with the
primary responsibility and authority in the valuation and compensation of covered landholdings to carry out
the full implementation of the Agrarian Reform Program.
G.R. NO. 171972, JUNE 8, 2011

FACTS: The case stemmed from the complaint filed by respondent for unlawful detainer against petitioners.
Respondent alleged that she is the absolute owner of the land issued by virtue of a free patent in the name
of her predecessors-in-interest, and despite several verbal and written demands, petitioners refused to
vacate. Petitioners, on the other hand, argued that they entered the land with the consent of the
respondents’ predecessors-in-interest under the agreement that the property shall be devoted to
agricultural production and the produce shall be shared with them. Since there is a tenancy relationship
with the parties, the DARAB should handle such case and the MTC had no jurisdiction over the matter. The
MTC and the RTC found no tenurial relationship between the parties and dismissed the case for lack of
jurisdiction. The CA found no agricultural tenancy existed between the predecessors of the respondent and
the petitioners and ruled that the affidavits merely showed that they occupied the lands with the consent of
the owners and since they were occupying such lands by mere tolerance, they were bound to vacate the
land upon demand.

ISSUE: Whether or not there exist a tenurial relationship between the petitioners and the respondents’

HELD: The Court held in the negative. Agricultural tenancy exists when all the following requisites are
present: 1) the parties are the landowner and the tenant or agricultural lessee; 2) the subject matter of the
relationship is an agricultural land; 3) there is consent between the parties to the relationship; 4) the purpose
of the relationship is to bring about agricultural production; 5) there is personal cultivation on the part of the
tenant or agricultural lessee; and 6) the harvest is shared between landowner and tenant or agricultural
lessee. The Court found that there was no other evidence given in support with the claim that the
respondents’ predecessors consented to the tenurial relationship. The affidavits were only self-serving.
Furthermore, the petitioner fail to present sufficient evidence to prove that they were sharing the harvest
with the owners of the land. As we have often said, mere occupation or cultivation of an agricultural land
will not ipso facto make the tiller an agricultural tenant.[47] It is incumbent upon a person who claims to be
an agricultural tenant to prove by substantial evidence all the requisites of agricultural tenancy.
G.R. NO. 171840, APRIL 4, 2011

FACTS: Respondent offered to sell his three parcels of agricultural land with an aggregate area of 33.5617
hectares under the provisions of CARL. They presented as assessment of 300,000 per hectare but the
petitioners assessed the entire for only 4,669,259.92 Php. Respondents rejected the evaluation and
proceeded to DARAB for the determination of the lands. The DAR held that the aggregate sum should be
5,580,000 Php or 180,000 per hectare. It also found that contention of petitioners that the valuation should
be in coherence with DAR AO No. 5 of 1998 untenable as it contravened with the declaration of the court
in LBP vs CA that any formula or guidelines promulgated by the bank was a violation of the due process of
the Constitution. Respondents filed before the Special Agrarian Court and found that the LBP should pay
respondents of the following amounts for the hectares of land: for T.C.T. No. T-291208 - P3,089,416.13,
for T.C.T. No. T-291209 - P 297,177.50, and for T.C.T. No. T-291210 - P2,907,041.87on the basis that in
2001 the price for palay was between 9 and 10 php per kilogram under DAR AO No. 5. On Appeal, the CA
affirmed the decision of the SAC.

ISSUE: Whether or not the DAR has the power to issue the rules and regulations issued under the CARL.

HELD: The court held in the affirmative. The court declared in and Bank of the Philippines v. Celada that
the DAR was tasked to issue the rules and regulations to carry out the details of Section 17 of R.A. No.
6657. It can be safely presumed that the fluctuations in the selling price of palay were already taken into
consideration since only the average of these available prices within the 12 months prior to the receipt of
the CF, will be used in computing the CNI. Hence, the SAC and CA clearly erred in completely disregarding
the data provided by the MARO simply because it contained a notation that the figures indicated for two
months (October and November 2000) were not normal due to typhoons