G.R. No. 196028. April 18, 2016.
SAMAHAN NG MAGSASAKA AT MANGINGISDA NG SITIO NASWE, INC. (SAMMANA), REPRESENTED BY ROGELIO A. COMMENDADOR, PRESIDENT, Petitioner, vs. TOMAS TAN, Respondent.

FACTS

The petitioner, Samahan ng Magsasaka at Mangingisda ng Sitio Naswe, Inc. (SAMMANA), is an association of farmers and fishermen residing in Sitio Talaga, Barangay Ipag, Mariveles, Bataan, whose members claimed to have resided and conducted farming activities on the land for years. The subject property is a 129.4227-hectare land in Barangay Ipag, previously owned by Anchor Estate Corporation, a dummy corporation of the late President Ferdinand E. Marcos, which was sequestered by the Presidential Commission on Good Government (PCGG). On June 16, 1994, a Notice of Coverage under the Comprehensive Agrarian Reform Program (CARP) was issued over this land. However, on April 4, 1995, the PCGG published an Invitation to Bid for the sale of 34 hectares of this property. Respondent Tomas Tan emerged as the highest bidder, and the sale was approved by the PCGG Committee on Privatization and the Office of the President (OP), culminating in a Deed of Sale executed on August 1, 2000. On July 25, 2000, the PCGG requested the Department of Agrarian Reform (DAR) to stop the CARP acquisition. Consequently, on July 26, 2000, DAR Secretary Horacio R. Morales, Jr. issued an Order lifting the Notice of Coverage and stopping the acquisition proceedings. On October 29, 2004, the petitioner filed a Petition to Revoke this DAR Order. The DAR denied the petition and a subsequent motion for reconsideration, ruling that the sequestered property, being government-owned, was not “private agricultural land” subject to CARP. The petitioner appealed to the OP, which dismissed the appeal on April 10, 2007. The petitioner then filed a Petition for Review with the Court of Appeals (CA). In its July 27, 2010 decision, the CA, while finding the lifting of the Notice of Coverage “irregular and erroneous,” dismissed the petition on the ground that the petitioner was not a real party in interest, as it failed to show its members were identified, registered, or approved CARP beneficiaries. The CA denied reconsideration.

ISSUE

Whether the petitioner, SAMMANA, is a real party in interest with the legal standing to question the July 26, 2000 DAR Order lifting the Notice of Coverage over the subject land.

RULING

The Supreme Court DENIED the petition and affirmed the CA’s dismissal. The petitioner is not a real party in interest.
A real party in interest is the party who stands to be benefited or injured by the judgment or is entitled to the avails of the suit, possessing a real, actual, material, or substantial interest, not a mere expectancy or future contingent interest. While Section 50 of Republic Act No. 6657 (the Comprehensive Agrarian Reform Law) in relation to the Rules of Court allows farmers’ organizations to represent their members in DAR proceedings, this must be harmonized with the requirement that the represented members themselves have a substantial interest in the subject matter.
The Court held that the petitioner failed to allege and prove that its members were identified and registered qualified CARP beneficiaries, approved awardees, or grantees of Certificates of Land Ownership Award (CLOAs) over the disputed property. The petitioner’s allegations were limited to its members being long-time residents and farmers in the area. Their interest was, at most, a mere expectancy that did not ripen into an actual award or ownership. The Court cited precedents (Fortich v. Corona, Sumalo Homeowners Association of Hermosa, Bataan v. Litton, and Samahang Magsasaka ng 53 Hektarya v. Mosquera) which uniformly ruled that mere farmer-beneficiaries who are not approved awardees or CLOA grantees are not real parties in interest. The fact that the processing of the members’ case folders was halted by the DAR Order did not vest any right in them. Consequently, lacking the requisite legal standing, the petitioner’s petition was properly dismissed.