GR 232863; (July, 2019) (Digest)
G.R. No. 232863 July 24, 2019
GOVERNMENT SERVICE INSURANCE SYSTEM, Petitioner vs. MUNICIPAL AGRARIAN REFORM OFFICER ROMERICO DATOY, Respondent
FACTS
Metro Davao Agri-Hotel Corporation obtained a loan from the Government Service Insurance System (GSIS), secured by a mortgage over two parcels of land, one of which was agricultural. Upon the corporation’s default, GSIS foreclosed and consolidated ownership of the properties. In 2004, Municipal Agrarian Reform Officer Romerico Datoy issued a Notice of Coverage over the agricultural land for compulsory acquisition under the Comprehensive Agrarian Reform Program (CARP). GSIS protested and filed a Petition for Exclusion with the Department of Agrarian Reform (DAR), arguing its properties are exempt from agrarian reform.
The DAR Regional Director denied GSIS’s Petition. This denial was successively affirmed by the Agrarian Reform Secretary, the Office of the President, and the Court of Appeals. GSIS elevated the case to the Supreme Court via a Petition for Review on Certiorari, primarily invoking Section 39 of its charter, Republic Act No. 8291 (The GSIS Act of 1997), which exempts its assets and funds from “attachment, garnishment, execution, levy or other processes.”
ISSUE
Whether an agricultural land acquired by GSIS through foreclosure is exempt from compulsory coverage under the Comprehensive Agrarian Reform Law.
RULING
The Supreme Court denied the Petition and affirmed the lower rulings. The Court held that the subject land is not exempt from CARP coverage. The legal logic proceeds from a clear statutory interpretation. First, the Court clarified that Section 39 of RA 8291, which GSIS relied upon, pertains to exemptions from legal processes for the satisfaction of money claims against its members. It is not an exemption from the State’s sovereign power of eminent domain exercised through agrarian reform, which involves compulsory acquisition for a public purpose upon payment of just compensation.
Second, and decisively, the Court applied the express provisions of the Comprehensive Agrarian Reform Law ( Republic Act No. 6657 ). Section 4 of the law mandates that CARP shall cover “all public and private agricultural lands.” More specifically, Section 7 explicitly includes “lands foreclosed by government financial institutions” among the types of lands subject to immediate acquisition and distribution. The GSIS is unequivocally a government financial institution as defined under existing law. Since the land in question is agricultural and was acquired by GSIS via foreclosure, it falls squarely within the coverage specified in Section 7. The law’s inclusive list does not provide an exemption for such lands. Therefore, the land is subject to compulsory agrarian reform coverage.