GR 158228; (March, 2004) (Digest)
G.R. No. 158228 ; March 23, 2004
DEPARTMENT OF AGRARIAN REFORM, represented by Secretary ROBERTO M. PAGDANGANAN, petitioner, vs. DEPARTMENT OF EDUCATION, CULTURE AND SPORTS (DECS), respondent.
FACTS
The subject lands, Lots 2509 and 817-D in Negros Occidental, were donated to respondent DECS in 1921. DECS subsequently leased these agricultural lands, planted to sugarcane, to Anglo Agricultural Corporation. In 1993, farm workers petitioned for the land’s coverage under the Comprehensive Agrarian Reform Program (CARP). The DAR Regional Director issued an order placing the lands under CARP coverage, which was affirmed by the Secretary of Agrarian Reform. DECS appealed to the Court of Appeals, arguing the lands were exempt because the lease income was used for educational purposes. The CA set aside the DAR’s decision, prompting the DAR to elevate the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the subject landholdings owned by DECS are exempt from the coverage of the Comprehensive Agrarian Reform Law ( R.A. No. 6657 ).
RULING
The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the DAR Secretary’s decision. The lands are not exempt and are subject to CARP coverage. The legal logic is anchored on the clear provisions of Section 10 of R.A. No. 6657 , which enumerates exempt lands. For government-owned lands, the exemption under Section 10 applies only to those “actually, directly, and exclusively used and found to be necessary for” specific purposes like national parks or government research centers. The Court emphasized that for the exemption of lands owned by government educational institutions to apply, it is the land itself that must be actually, directly, and exclusively used for educational purposes, such as for school sites or campuses. In this case, the lands were not used as a school site but were leased to a private corporation for agricultural production. The fact that the income derived from the lease was used for educational purposes is irrelevant and does not satisfy the statutory requirement for exemption. The lands, being agricultural and part of the public domain suitable for agriculture, fall squarely within the coverage of CARP as defined in Section 4 of the law. The identification of farmer-beneficiaries, having been certified by the Barangay Agrarian Reform Council (BARC) and processed by the DAR, involves administrative implementation where no grave abuse of discretion was found.