G.R. No. 132073 & 132361. October 06, 2021.
REMMAN ENTERPRISES, INC., PETITIONER, VS. HON. ERNESTO D. GARILAO, IN HIS CAPACITY AS SECRETARY OF THE DEPARTMENT OF AGRARIAN REFORM, EDUARDO ADRIANO, ET AL., RESPONDENTS. [G.R. No. 132361] EDUARDO ADRIANO, ET AL., PETITIONERS, VS. REMMAN ENTERPRISES, INC., AND HON. ERNESTO D. GARILAO, IN HIS CAPACITY AS SECRETARY OF AGRARIAN REFORM, RESPONDENTS.

FACTS

Parcels of land with an aggregate area of 46.9180 hectares in Brgy. San Jose, Dasmariñas, Cavite were owned by the Saulogs. In 1989, the parcels, covered by Operation Land Transfer (OLT), were distributed to farmer-beneficiaries (respondents Adriano, et al.) and emancipation patents (EPs) were issued to them. On February 6, 1993, the Saulogs filed a Petition for Annulment of the EPs and other documents (DARAB Case No. IV-Ca-0087-92) concerning a 27.8530-hectare portion. On February 7, 1995, while the DARAB case was pending, the Saulogs sold the entire 46.9180-hectare land to petitioner Remman Enterprises, Inc. Consequently, Remman intervened in the DARAB case. On August 17, 1995, Remman filed with the DAR an application for exemption from CARP coverage of the purchased land, supported by certifications that the land was within a residential zone and was not irrigated. On June 5, 1996, DAR Secretary Ernesto D. Garilao issued an Order denying Remman’s application, placing the properties under CARP coverage. On September 4, 1996, Secretary Garilao issued another Order partially granting the application, exempting 31.59885 hectares but placing 15.31915 hectares (the share of Nieves vda. de Saulog) under CARP. Both Remman and the farmer-beneficiaries appealed to the Court of Appeals (CA). The CA, in its Decision dated April 30, 1997, set aside the September 4, 1996 Order and reinstated the June 5, 1996 Order denying the application in its entirety. The CA held that the land was covered by OLT under P.D. No. 27, that EPs had already been issued to the farmer-beneficiaries, and that the land was irrigated and therefore non-negotiable for conversion. The CA also noted that the sale to Remman was made while the annulment case was pending and that the land was already under CARP coverage when the application for exemption was filed. Motions for Reconsideration were denied. The Supreme Court initially held the petitions in abeyance pending a final determination on the validity of the EPs. The case was remanded to the Provincial Agrarian Reform Adjudicator (PARAD), which, in a Decision dated January 27, 2020, declared the EPs valid.

ISSUE

The core issue is whether the subject parcels of land are exempt from CARP coverage.

RULING

The Supreme Court DENIED the petition of Remman Enterprises, Inc. and GRANTED the petition of the farmer-beneficiaries (Adriano, et al.). The Court affirmed the validity of the emancipation patents issued to the farmer-beneficiaries and held that the subject land is covered by agrarian reform.
The Court ruled that the land is covered by Operation Land Transfer (OLT) under Presidential Decree No. 27. The issuance of Certificates of Land Transfer (CLTs) and subsequently Emancipation Patents (EPs) to the farmer-beneficiaries vested in them a vested right over the land, which cannot be defeated by a subsequent reclassification or application for exemption. The EPs, once registered, become indefeasible evidence of ownership. The Court upheld the PARAD’s finding that the EPs were validly issued. Furthermore, the Court found that the land was irrigated, making it non-negotiable for conversion under existing administrative orders. The application for exemption filed by Remman was therefore correctly denied. The sale of the land by the Saulogs to Remman in 1995 did not affect the coverage, as the land was already under OLT and EPs had been issued to the beneficiaries years prior. The Court also noted that the pendency of the annulment case did not suspend the implementation of agrarian reform. Thus, the Court of Appeals Decision reinstating the DAR Secretary’s Order denying the application for exemption in toto was affirmed.