The Supreme Court has affirmed that local government units (LGUs) had the authority to reclassify lands from agricultural to non-agricultural uses before the enactment of the Comprehensive Agrarian Reform Law (CARL) in 1988, without needing approval from the Department of Agrarian Reform (DAR). This ruling provides clarity on land use regulations, confirming that LGUs’ decisions on land reclassification made before the CARL’s effectivity are considered absolute. This decision impacts landowners and agrarian reform beneficiaries, particularly in areas where land use classifications have shifted over time.

From Rice Fields to Industrial Zones: Whose Land Use Plan Prevails?

This case, Heirs of Luis A. Luna and Remegio A. Luna, and Luz Luna-Santos vs. Ruben S. Afable, et al., revolves around a disputed landholding in Calapan City, Oriental Mindoro, originally classified as agricultural but later reclassified as a light intensity industrial zone by the local government. The petitioners, the Luna heirs, sought to exclude their land from the coverage of the Comprehensive Agrarian Reform Program (CARP), arguing that the reclassification occurred before the effectivity of Republic Act (RA) No. 6657, also known as the CARL. Respondents, identified as farmer-beneficiaries, contested this claim, asserting their rights to the land under the agrarian reform program. The central legal question is whether the local government’s reclassification of the land prior to June 15, 1988, effectively exempted it from CARP coverage, regardless of subsequent DAR actions.

The legal framework governing this case is multifaceted, drawing from agrarian reform laws, local government autonomy, and administrative regulations. Section 4 of RA No. 6657 defines the scope of the CARL, covering both public and private agricultural lands. However, Section 3(c) of the same law defines “agricultural land” as land devoted to agricultural activity and not classified as mineral, forest, residential, commercial, or industrial land. This definition is crucial as it carves out an exception for lands already designated for non-agricultural uses.

The Department of Agrarian Reform (DAR) Administrative Order No. 1, Series of 1990, further clarifies the meaning of “agricultural lands” covered by the CARL. It specifies that lands classified in town plans and zoning ordinances as residential, commercial, or industrial by the Housing and Land Use Regulatory Board (HLURB) or its predecessors before June 15, 1988, are not considered agricultural lands. This administrative order reinforces the principle that land reclassification prior to the CARL’s effectivity takes precedence.

The Supreme Court emphasized the authority of local government units (LGUs) to reclassify agricultural lands. Section 3 of RA No. 2264, the Local Autonomy Act of 1959, empowers municipal and city councils to adopt zoning and subdivision ordinances, subject to certain approvals. This grant of authority allows LGUs to regulate land use within their jurisdictions, reflecting a policy of decentralization and local autonomy. The Court acknowledged that the power of local legislatures to regulate land use through zoning and reclassification is an exercise of police power. Ordinance No. 21 of the Sangguniang Bayan of Calapan, which reclassified the land in question, was deemed a valid exercise of this power.

In this case, Ordinance No. 21, series of 1981, reclassified certain areas in Calapan, including portions of Barangay Guinobatan, into a light intensity industrial zone. This ordinance was based on a Development Plan and Zone District Plan adopted by the Sangguniang Bayan and approved by the HLURB through Resolution No. R-39-4, series of 1980. The Court found that this approval satisfied the requirement that zoning ordinances be approved by the HLURB or its predecessor agency prior to June 15, 1988. The primary issue, then, was whether the petitioners’ land fell within the reclassified zone.

To resolve this issue, the Court examined certifications issued by the Office of the Deputized Zoning Administrator and the Housing and Urban Development Coordinating Council (HUDCC). Former DAR Secretary Pagdanganan relied on these certifications in granting the petitioners’ application for exemption from CARP coverage. The Court noted that while DAR AO No. 6 required a certification from the HLURB, the HUDCC certification was sufficient since the HLURB is an agency under the HUDCC. Crucially, the HUDCC certification stated that a significant portion of the petitioners’ land was within the Light Industrial Zone.

The Supreme Court gave greater weight to the certification of the zoning administrator, emphasizing their specialized knowledge of the area. This certification carried a presumption of regularity, which the respondents failed to overcome. The Court emphasized that specialized agencies tasked with determining land classification, such as the HUDCC and the Deputized Zoning Administrator, are entitled to great respect. The Court contrasted these certifications with the findings of former DAR OIC Secretaries Ponce and Pangandaman, who relied on factors such as irrigation and land slope to conclude that the land was agricultural. The Supreme Court clarified that such factors are only relevant if the land is already classified as agricultural. Since the land in question had been reclassified as industrial, these factors were deemed immaterial.

The respondents argued that the petitioners’ land was not included in the light intensity industrial zone under Ordinance No. 21. However, they failed to provide any maps or other evidence to support this claim. The Court noted that the best evidence would have been a map showing the metes and bounds of the land, but the respondents did not submit such evidence. In the absence of such evidence, the Court relied on the certifications of the appropriate government agencies with expertise in land classification. The Supreme Court ultimately concluded that the petitioners had positively established that their property was no longer agricultural when the CARL took effect and was therefore exempt from agrarian reform.

The Supreme Court’s decision reinforces the principle of local autonomy in land use planning and clarifies the interplay between agrarian reform and local government regulations. Landowners benefit from the certainty that land reclassifications made by LGUs before the CARL’s effectivity will be respected. Conversely, agrarian reform beneficiaries may find that certain lands are excluded from CARP coverage due to prior reclassifications. The ruling highlights the importance of consulting local zoning ordinances and land use plans to determine the status of land under the CARL. This decision underscores the need for clear and consistent land use policies at both the local and national levels. It also recognizes the evolution of land use over time and the authority of local governments to adapt to changing needs.

FAQs

What was the key issue in this case?	The key issue was whether the local government’s reclassification of the land from agricultural to industrial use prior to the effectivity of the Comprehensive Agrarian Reform Law (CARL) exempted it from CARP coverage.
When did the local government reclassify the land?	The land was reclassified through Ordinance No. 21, series of 1981, enacted by the Sangguniang Bayan of Calapan, Oriental Mindoro. The HLURB approved the ordinance on July 31, 1980.
What is the significance of June 15, 1988?	June 15, 1988, is the date of effectivity of the Comprehensive Agrarian Reform Law (CARL). Land reclassifications made before this date are generally considered to be outside the coverage of CARP.
What role did the Housing and Land Use Regulatory Board (HLURB) play?	The HLURB’s approval of the local zoning ordinance (Ordinance No. 21) was crucial. The approval validated the reclassification of the land for non-agricultural uses prior to the effectivity of CARL.
What evidence did the petitioners use to support their claim?	The petitioners primarily relied on certifications from the Office of the Deputized Zoning Administrator and the Housing and Urban Development Coordinating Council (HUDCC) to prove the land’s reclassification.
Why did the Supreme Court favor the zoning administrator’s certification?	The Court favored the zoning administrator’s certification because they have specialized knowledge of the area and the certification carried a presumption of regularity. They also have jurisdiction over the land where the questioned property is situated.
What is the practical implication of this ruling for landowners?	This ruling provides certainty for landowners whose properties were reclassified by local governments before June 15, 1988. This means that these lands are likely exempt from CARP coverage.
How does this ruling affect agrarian reform beneficiaries?	Agrarian reform beneficiaries may find that certain lands they expected to be covered by CARP are excluded due to prior local government reclassifications, potentially limiting their land acquisition opportunities.
What is the role of the Department of Agrarian Reform (DAR) in these cases?	While DAR generally oversees agrarian reform, this case confirms that it cannot override valid land reclassifications made by local governments prior to June 15, 1988.

This case clarifies the balance between agrarian reform and local land use planning, underscoring the importance of historical land classifications. The decision emphasizes that local government authority, when properly exercised before the enactment of CARL, is paramount. This ruling offers valuable guidance for landowners, agrarian reform beneficiaries, and local government units alike.

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: HEIRS OF LUIS A. LUNA VS. RUBEN S. AFABLE, G.R. No. 188299, January 23, 2013