GR 167952; (October, 2016) (Digest)
G.R. No. 167952, October 19, 2016
GONZALO PUYAT & SONS, INC., PETITIONER, VS. RUBEN ALCALDE (DECEASED), SUBSTITUTED BY GLORIA ALCALDE, REPRESENTATIVE OF THE FARMER-BENEFICIARIES, RESPONDENT.
FACTS
The Department of Agrarian Reform (DAR) issued a Notice of Coverage and a subsequent Notice of Valuation and Acquisition over a 37.7353-hectare property owned by Gonzalo Puyat & Sons, Inc. The petitioner sought exemption, arguing the land was industrial, uncultivated, and bought in good faith. The DAR Secretary dismissed the petition, declaring the land agricultural and within CARP coverage. An Order of Finality was issued. Petitioner appealed to the Office of the President (OP), which set aside the DAR Orders and lifted the Notices, directing an ocular inspection. The OP Decision became final.
Respondents elevated the case to the Court of Appeals (CA), which reinstated the DAR Orders. The Supreme Court, in a 2012 Decision, reversed the CA and reinstated the OP Decision. Respondents filed a Motion for Reconsideration, which is the subject of this Resolution.
ISSUE
Whether the Supreme Court should reconsider its February 1, 2012 Decision and affirm the inclusion of the subject landholding under the Comprehensive Agrarian Reform Program (CARP).
RULING
The Supreme Court GRANTED the Motion for Reconsideration, SET ASIDE its 2012 Decision, and REINSTATED the CA Decision which affirmed the DAR Orders. The Court held that the land is subject to CARP coverage. The legal logic centered on the timeliness of the land’s reclassification and the conclusive nature of the DAR’s factual findings. The petitioner’s claim of industrial classification was based on a 1997 municipal ordinance. However, the Court found this reclassification ineffective for exempting the land from CARP as it occurred after the effectivity of Republic Act No. 6657 (the CARP Law) on June 15, 1988. For exemption based on reclassification to be valid, the land must have been reclassified prior to CARP’s effectivity. Furthermore, the DAR Secretary’s finding that the land was agricultural, based on evidence including its slope and actual use for palay cultivation, is a factual determination accorded great weight and finality when supported by substantial evidence. The OP erred in overturning these findings and ordering a new ocular inspection, as the DAR’s factual conclusions were already conclusive. Thus, the subject property is rightfully covered by agrarian reform.