GR 181055; (March, 2014) (Digest)
G.R. No. 181055 March 19, 2014
HEIRS OF TERESITA MONTOYA, represented by JOEL MONTOYA, HEIRS OF PATRICIO OCAMPO, represented by VIOLETA OCAMPO, and BARTOLOME OCAMPO, Petitioners, vs. NATIONAL HOUSING AUTHORITY, DORITA GONZALES and ERNESTO GONZALES, in his capacity and as attorney-in-fact, Respondents.
FACTS
The case involves a 129.62-hectare property in Pampanga, originally part of a 402-hectare landholding owned by the Gonzales family. In 1992, the Gonzaleses donated a portion of their landholding as a resettlement site for Mt. Pinatubo eruption victims, retaining the subject property. On February 20, 1996, the National Housing Authority (NHA) purchased the retained property for use as an additional resettlement site. The Department of Agrarian Reform (DAR) approved the NHA’s application for conversion of the property from agricultural to residential use on November 30, 1996. The petitioners, claiming to be registered tenants under the Operation Land Transfer (OLT) program per a 1996 Municipal Agrarian Reform Officer (MARO) certification, filed a Complaint for Injunction and Declaration of Nullity of Deed of Absolute Sale. They argued the 1992 donation and 1996 sale circumvented agrarian laws, that they had attained “deemed ownership” via Certificates of Land Transfer (CLTs), and that the NHA destroyed their rice paddies. The Provincial Agrarian Reform Adjudicator (PARAD) denied the complaint, ruling the conversion was valid and the property was exempt from agrarian reform as an NHA-acquired resettlement site under P.D. No. 1472, and that CLTs are not proof of absolute ownership. The DARAB and the Court of Appeals affirmed the PARAD’s decision.
ISSUE
The core issue is whether the NHA’s acquisition and conversion of the agricultural property for a resettlement project is valid, thereby removing it from the coverage of the Comprehensive Agrarian Reform Program (CARP), despite the petitioners’ claim of being tenants with rights under the agrarian reform program.
RULING
The Supreme Court denied the petition, affirming the lower courts’ decisions. The Court held:
1. The property was validly converted from agricultural to residential use upon the DAR’s approval of the NHA’s application. This conversion legally removed the land from CARP coverage.
2. The property is exempt from CARP coverage under P.D. No. 1472, which exempts lands acquired by the NHA for its resettlement projects. This exemption applies regardless of whether the acquisition occurred before or after the effectivity of the Comprehensive Agrarian Reform Law (CARL).
3. The petitioners’ claim of “deemed ownership” based on CLTs is untenable. A CLT is merely a provisional document evidencing the holder’s qualification for land ownership under agrarian reform, not a title of absolute ownership. The issuance of CLTs does not automatically vest ownership, especially over land that is later validly converted or exempted.
4. The property constituted the Gonzales family’s retained area under Section 6 of R.A. No. 6657 . As landowners, they had the right to retain this area, and its subsequent sale to the NHA for a public purpose was valid.
5. The petition raised factual issues inappropriate for a Rule 45 review, as the findings of the PARAD, DARAB, and CA were unanimous and supported by substantial evidence.