G.R. No. 200491 , June 9, 2014
KASAMAKA-CANLUBANG, INC., represented by PABLITO M. EGILDO, Petitioner, vs. LAGUNA ESTATE DEVELOPMENT CORPORATION, Respondent.

FACTS

Respondent Laguna Estate Development Corporation (LEDC) obtained a conversion order from the Ministry of Agrarian Reform on June 4, 1979, allowing the conversion of ten parcels of land from agricultural to residential use, subject to conditions including the commencement of development within two years. On July 4, 2004, petitioner KASAMAKA-Canlubang, Inc. filed a petition with the Department of Agrarian Reform (DAR) for the revocation of this conversion order, alleging respondent’s failure to develop the lands. On September 25, 2006, the DAR Secretary issued an Order partially revoking the conversion order for eight of the ten parcels. Respondent filed a motion for reconsideration, arguing these lands were exempt from the Comprehensive Agrarian Reform Law (CARL) due to municipal zoning ordinances reclassifying them as non-agricultural. An ocular inspection on June 10, 2008, found that two of the eight parcels remained undeveloped, but the DAR committee concluded that, except for one parcel, respondent failed to substantially comply with the development condition. On August 8, 2008, the DAR Secretary affirmed the revocation order for seven parcels. Respondent appealed to the Office of the President (OP), which granted the appeal on March 23, 2009, reinstating the conversion order and declaring the seven parcels exempt from CARL coverage. The Court of Appeals dismissed petitioner’s subsequent appeal on June 27, 2011.

ISSUE

Whether the Court of Appeals erred in ruling that the undeveloped areas of the landholdings subject to the 1979 conversion order could no longer be considered agricultural lands and in failing to consider that the conversion order and municipal zoning ordinances did not ipso facto change the nature of existing agricultural lands or the legal relationships over them.

RULING

The Supreme Court denied the petition. It held that the findings of fact by the Court of Appeals, which are supported by substantial evidence, are conclusive and binding. The Court’s jurisdiction in a petition for review on certiorari under Rule 45 is limited to questions of law. The petitioner failed to demonstrate that the case falls under any recognized exception warranting a re-evaluation of the factual findings. The Court agreed with the Court of Appeals that the DAR Secretary’s revocation order was based on inconsistent findings, as the ocular inspection report indicated only two parcels were undeveloped, yet the order revoked seven. Furthermore, the petitioner failed to submit sufficient supporting evidence, such as the original site development plan, to substantiate its claim of non-compliance, thereby failing to meet its burden of proof. The Office of the President correctly found that respondent presented satisfactory evidence of development activities, including existing road networks and other improvements, constituting commencement of development as required by the conversion order. The Court also noted that municipal zoning ordinances reclassifying the lands prior to the effectivity of the CARL rendered them outside its coverage.