G.R. No. 139285; December 21, 2007
ROMAN CATHOLIC ARCHBISHOP OF CACERES, Petitioner, vs. SECRETARY OF AGRARIAN REFORM and DAR REGIONAL DIRECTOR (Region V), Respondents.

FACTS

The petitioner, the Roman Catholic Archbishop of Caceres, is the registered owner of 268.5668 hectares of agricultural land in Camarines Sur, with 249 hectares planted to rice and corn. In 1985, he filed petitions for exemption from Operation Land Transfer under P.D. No. 27, arguing the lands were acquired via donations prohibiting their sale, encumbrance, or mortgage and were used for charitable and religious purposes to support seminaries, churches, and mission work. The DAR denied the petitions and subsequent appeals, a decision affirmed by the Court of Appeals.
Before the Supreme Court, the Archbishop contended he was not the absolute “landowner” under agrarian law but a mere trustee holding naked title for the benefit of the church’s followers as cestui que trust. He argued that the conditional donations created an express trust, making him an administrator, and thus, the lands should be exempt from coverage. Alternatively, he prayed that each beneficiary of the trust be accorded a separate right of retention.

ISSUE

Whether the petitioner, as a registered landowner holding title under alleged trust arrangements for religious purposes, is entitled to exemption from agrarian reform coverage or to multiple rights of retention for the purported beneficiaries.

RULING

The Supreme Court denied the petition and affirmed the lower rulings. The Court held that for agrarian reform purposes, the law defines “landowner” simply as the registered owner, without qualification as to the nature of the title or any attendant fiduciary obligations. Since the Archbishop undisputedly holds the registered titles, he is conclusively deemed the landowner under P.D. No. 27 and R.A. No. 6657 (CARL). The Court refused to look beyond the certificates of title to examine conditions in the deeds of donation, as doing so would create a judicial exemption not found in the law and allow landowners to easily circumvent agrarian reform by imposing conditions on donations.
The Court further ruled that the law does not permit a single registered owner to assert multiple rights of retention on behalf of alleged beneficiaries. Both agrarian laws clearly provide for a single retention limit per landowner. Adopting the petitioner’s theory would frustrate the constitutional and revolutionary intent of agrarian reform to redistribute land to the landless. The charitable and religious use of the land does not constitute a legal exemption, and just compensation is provided. The noble goals of the Comprehensive Agrarian Reform Law must not be stymied by exceptions not contemplated by the statute.