The Supreme Court ruled that the Comprehensive Agrarian Reform Law (CARL) does not cover lands reclassified for residential or industrial use before June 15, 1988, the date CARL took effect. This decision underscores the primacy of local zoning ordinances and prior government approvals in land use classification. The ruling reaffirms the rights of landowners who had their properties reclassified before CARL’s enactment, ensuring that these properties are not subject to agrarian reform.

From Farms to Homes: Zoning Authority vs. Agrarian Reform

The case revolves around a property in Carmona, Cavite, originally acquired by Lakeview Development Corporation (LDC) in 1964 and later transferred to Credito Asiatic, Incorporated (CAI). CAI sought to develop the 75-hectare property into a residential and industrial estate. The Municipal Council of Carmona approved the zoning and subdivision plan in 1976. The project, known as the Tamanli Housing Project, aimed to provide low-cost housing. CAI obtained necessary clearances and licenses from various government agencies, including the National Housing Authority (NHA) and the Human Settlements Regulatory Commission (HSRC). Subsequently, a dispute arose when Pasong Bayabas Farmers Association, Inc. (PBFAI) claimed tenancy rights over the property and sought coverage under the Comprehensive Agrarian Reform Law (CARL).

CAI faced legal challenges when PBFAI filed a complaint for Maintenance of Peaceful Possession and Cultivation with Damages, seeking to prevent the bulldozing of the property. The Provincial Agrarian Reform Adjudicator (PARAD) initially ruled in favor of CAI, finding that PBFAI members were not bona fide tenants. The Department of Agrarian Reform Adjudication Board (DARAB) reversed this decision, declaring the landholding covered by CARL. This divergence in rulings prompted CAI to seek recourse with the Court of Appeals, which sided with CAI, reinstating the PARAD’s decision. PBFAI and DARAB then elevated the matter to the Supreme Court.

At the heart of the legal battle was the question of whether the property was subject to CARL coverage, given its reclassification as residential land before CARL’s enactment. The petitioners argued that the reclassification required HSRC approval and that DAR has exclusive authority to reclassify land. The respondent countered that the Municipal Council of Carmona validly reclassified the land in 1976 and various government agencies supported the reclassification. The Supreme Court examined the legal framework governing land use classification. Under Section 3(c) of Rep. Act No. 6657, agricultural lands refer to lands devoted to agriculture and not classified as industrial, commercial, or residential. Section 4(e) extends coverage to private lands suitable for agriculture, irrespective of products raised. However, this law took effect on June 15, 1988. In this case, crucial administrative actions occurred before this date.

Section 3 of Rep. Act No. 2264, amending the Local Government Code, specifically empowers municipal and/or city councils to adopt zoning and subdivision ordinances or regulations in consultation with the National Planning Commission. A zoning ordinance prescribes, defines, and apportions a given political subdivision into specific land uses as present and future projection of needs.

The Court found that, well before the effectivity of Rep. Act No. 6657, the property had already been reclassified from agricultural to non-agricultural by several government agencies. These included the Bureau of Lands, the National Planning Commission, and the Municipal Council of Carmona. Additionally, Agrarian Reform Minister Conrado F. Estrella had approved the conversion of a portion of the property for the Hakone Housing Project in 1979, determining it was untenanted and suitable for residential use. As the Supreme Court stated in Natalia Realty Inc. and Estate Developers and Investors Corp. v. Department of Agrarian Reform, et al., “agricultural lands are only those lands which are ‘arable and suitable agricultural lands’ and ‘do not include commercial, industrial and residential lands.’ “ Therefore, lands not devoted to agricultural activity are outside the coverage of CARL.

Building on this, the Court underscored that the power of local government units to reclassify lands is not subject to DAR approval. As the court pointed out, reliance on Section 65 of Rep. Act No. 6657 is misplaced. Section 65 applies only to applications by landlords or beneficiaries to convert lands placed under agrarian reform after five years from its award. It does not apply to agricultural lands already converted as residential lands prior to the passage of Rep. Act No. 6657. Since the property had been classified as residential since 1976, DARAB lacked jurisdiction. The Court emphasized that PBFAI members were not tenants of CAI and therefore had no cause of action against the private respondent. Thus, their complaint must be dismissed.

FAQs

What was the key issue in this case?	The central issue was whether the Comprehensive Agrarian Reform Law (CARL) covers land reclassified from agricultural to residential before June 15, 1988, the date CARL took effect.
What did the Supreme Court decide?	The Supreme Court ruled that CARL does not apply to lands reclassified for residential use before June 15, 1988, upholding the local government’s authority to reclassify land.
What is the significance of the date June 15, 1988?	June 15, 1988, is the date when the Comprehensive Agrarian Reform Law (CARL) took effect, making it the pivotal point for determining land coverage under the law.
Who has the authority to reclassify agricultural land?	Local government units have the authority to reclassify agricultural land, and this authority does not require approval from the Department of Agrarian Reform (DAR) for reclassifications made before CARL’s enactment.
What constitutes agricultural land under Rep. Act No. 6657?	Under Rep. Act No. 6657, agricultural land refers to land devoted to agricultural activity and not classified as mineral, forest, residential, commercial, or industrial.
What was the basis for the DARAB’s initial decision?	The DARAB initially decided that the land was covered by CARL, which the Court of Appeals then overturned.
What criteria must be met to establish a tenancy relationship?	Key criteria include a landowner-tenant relationship, agricultural land as the subject, mutual consent, agricultural production as the relationship’s purpose, personal cultivation by the tenant, and shared harvest between landowner and tenant.
What happened to the members of the Pasong Bayabas Farmers Association (PBFAI)?	The Court ordered the members of PBFAI and all those occupying the property to vacate the landholding.

This Supreme Court decision clarifies the scope and limitations of agrarian reform in the context of prior land reclassification. By affirming the local government’s zoning authority and the validity of pre-existing land use conversions, the Court provides a legal framework that respects both property rights and local governance. This ruling helps clarify land use rights for property owners.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Pasong Bayabas Farmers Association, Inc. vs. Court of Appeals, G.R. No. 142359, May 25, 2004