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Case digest · DARAB jurisdiction despite LGU reclassification; requirements for a valid reclassification
Laynesa vs. Uy
Santos Laynesa had been a tenant on a farm in Pili, Camarines Sur since 1938, later joined by his son Nicolas. After the land was sold, the municipality reclassified it as industrial, and the buyers said the agrarian board could no longer hear the tenants’ case.
Facts
1938–1947
Robert Morley owned a four-hectare parcel in Pili, Camarines Sur, with Santos Laynesa as his tenant over two and a half hectares. In 1947 Morley sold the land to Sixto Cuba, Sr., who kept Santos as tenant and made Santos’s son, Nicolas, tenant over the rest.
January 13, 1993
Sixto Cuba, Jr., one of Cuba, Sr.’s children, sold the property to Pacita Uy, married to Paquito Uy, for PhP 80,000, by a deed of absolute sale that was not registered.
1993–1994
Pacita demanded that the Laynesas vacate the land. The Laynesas filed a petition with the DAR Adjudication Board (DARAB) to redeem it, and Pacita filed her own DARAB complaint for collection of rentals and ejectment. In February 1994 the Laynesas consigned PhP 80,000 as the redemption price.
1994–1995
In a separate suit to annul the sale, brought by other heirs of Cuba, Sr., a compromise approved by the Regional Trial Court gave the spouses Uy two hectares of rice lands, later titled in their names. Pacita obtained certifications from the Municipal Agricultural Office that the property was not prime agricultural property, and from the Municipal Agrarian Reform Office that the titled portion was not covered by Operation Land Transfer under PD 27.
May 29, 1995
The municipal council approved a resolution embodying an ordinance that reclassified the land from agricultural to industrial.
1995–2001
The Laynesas filed a DARAB complaint for threatened ejectment and redemption. The spouses Uy answered that the DARAB had no jurisdiction because the land had been reclassified. The provincial adjudicator allowed the Laynesas to redeem the two hectares for P60,000.00, and the DARAB affirmed but set aside the damages. On May 16, 2001, the Court of Appeals reversed, holding that the DARAB had no jurisdiction because the land had been reclassified.
Issue
Does the reclassification of agricultural land by a municipal ordinance, without the DAR’s approval, oust the DARAB of jurisdiction over the tenants’ petition for redemption, and was the reclassification valid?
Ruling
The DARAB kept jurisdiction, and the reclassification was not shown to be valid. The Court granted the petition, reversed the Court of Appeals and affirmed the DARAB, deleting the awards of damages and fees.
Jurisdiction is determined by the statute in force when the action is filed and by the allegations of the complaint. The tenants’ complaint for threatened ejectment and redemption was an agrarian reform matter within the DAR’s jurisdiction under Sec. 50 of R.A. No. 6657, and Sec. 20(e) of the Local Government Code left that section unrepealed. So the DARAB kept jurisdiction even though the landowners raised reclassification as a defense. The spouses Uy also failed to prove a valid reclassification. A certification that the lot was not “prime agricultural property” is not the Department of Agriculture’s certification that the land has ceased to be economically feasible and sound for agricultural purposes; a certification limited to PD 27 does not show that the land was not distributed under R.A. No. 6657 or covered by a notice of coverage; and there was no showing of compliance with MC 54, such as the HLURB’s report and recommendation, the public hearings and the Department of Agriculture’s report and recommendation. The tenants could redeem the two hectares, but the damages and fees were deleted: relying on the ordinance and the presumption that official duty was regularly performed, the spouses Uy did not act in bad faith.
“In view of the foregoing reasons, we rule that the DARAB retains jurisdiction over disputes arising from agrarian reform matters even though the landowner or respondent interposes the defense of reclassification of the subject lot from agricultural to non-agricultural use.”
Doctrine
A tenant’s case for threatened ejectment and redemption remains an agrarian reform matter within the DARAB’s jurisdiction even after an LGU reclassifies the land, because nothing in Sec. 20 of the Local Government Code shall be construed “as repealing, amending or modifying in any manner the provisions of [RA] 6657.” LGUs may reclassify agricultural land, but the reclassification is valid only if the requirements of Sec. 20 of R.A. No. 7160 and MC 54 are met, and the party relying on it must prove them.
Compare: before June 15, 1988
In Farmer-Beneficiaries Belonging to the Samahang Magbubukid ng Bagumbong vs. Heirs of Juliana Maronilla, G.R. No. 229983, July 29, 2019, the land had been reclassified in 1981, before the CARP law took effect, and its residential and institutional portions were exempted: “Thus, lands already classified as commercial, industrial or residential before June 15, 1988 no longer need any conversion clearance from the DAR in order to be exempt from CARP coverage.”
Bar tip
Pleading reclassification does not take a tenant’s case away from the DARAB. And a reclassification stands only if the Sec. 20 and MC 54 requirements are proved: a certification that the land is not “prime agricultural property” is not a Department of Agriculture certification that farming it is no longer economically feasible.
Hear it explained
Land Titles Jurisprudence Ep. 3, at 9:00
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This digest is general legal information for education, not legal advice, and it is not a substitute for reading the decision. Quoted passages are taken word for word from the full text.