G.R. No. 188174 , June 29, 2015
DEPARTMENT OF AGRARIAN REFORM, through its PROVINCIAL AGRARIAN REFORM OFFICER OF DAVAO CITY, and THE MUNICIPAL AGRARIAN REFORM OFFICER OF CALINAN, DAVAO CITY, Petitioners, vs. WOODLAND AGRO-DEVELOPMENT, INC., Respondent.

FACTS

Respondent Woodland Agro Development, Inc. is the registered owner of a 10.0680-hectare agricultural land in Davao City. On December 11, 2003, petitioner Department of Agrarian Reform (DAR) issued a Notice of Coverage (NOC) placing 5.0680 hectares under the coverage of the Comprehensive Agrarian Reform Law (CARL) for exceeding the retention limit. Subsequently, on October 5, 2004, a Notice of Acquisition (NOA) was issued, the title was canceled, and new titles were issued in the name of the Republic of the Philippines, with Certificates of Land Ownership Award (CLOAs) later issued to farmer beneficiaries. Woodland filed a complaint before the Regional Trial Court (RTC) seeking annulment of the NOC and NOA, contending that the DAR’s authority to issue such notices expired on June 15, 1998, based on Section 5 of Republic Act No. 6657 (CARL), which stated that land distribution “shall be implemented immediately and completed within ten (10) years” from its effectivity on June 15, 1988. Woodland argued that Republic Act No. 8532 , which amended the CARL, pertained only to funding and did not extend the period for land acquisition. The RTC ruled in favor of Woodland, nullifying the NOC and NOA, and held that R.A. 8532 did not extend the acquisition period beyond June 15, 1998. The DAR appealed to the Supreme Court.

ISSUE

Whether the DAR could still issue Notices of Coverage and Acquisition after June 15, 1998, or whether its authority to acquire private agricultural lands under the CARL expired after the ten-year implementation period.

RULING

The Supreme Court ruled that the DAR retained the authority to issue Notices of Coverage and Acquisition after June 15, 1998. The Court held that Republic Act No. 8532 extended the term for implementing the Comprehensive Agrarian Reform Program (CARP). The amendment to Section 63 of the CARL by R.A. 8532, which changed the funding source provision from “for the period of ten (10) years” to “until the year 2008,” referred to the implementation of the CARL in its entirety, not just its funding. This “until the year 2008” language unmistakably extended the DAR’s authority to acquire and distribute private agricultural lands. The Court further noted that the subsequent enactment of Republic Act No. 9700 , which extended land acquisition and distribution until June 30, 2014, presupposed that the CARP had not expired in 1998 and had already been extended to 2008 by R.A. 8532. The Court emphasized the constitutional mandate for agrarian reform and the need for faithful implementation to achieve social justice. Consequently, the Supreme Court reversed the RTC decision and upheld the validity of the Notice of Coverage dated December 11, 2003, and the Notice of Acquisition dated October 5, 2004.