In Spouses Benny Calvo and Jovita S. Calvo vs. Spouses Bernardito and Angelina Vergara and Spouses Alexberto and Belibeth Basalo, the Supreme Court affirmed the rights of farmer-beneficiaries to land redistribution, specifically upholding their entitlement to homelots under the Operation Land Transfer (OLT) program. The court reinforced that individuals who are validly reallocated farmlands are also entitled to homelots, even if those homelots are located outside the farmlots. This decision underscores the government’s commitment to agrarian reform and the protection of farmers’ rights, ensuring they have not only land for cultivation but also a place to call home. The ruling clarifies the scope of Presidential Decree No. 27 and Letter of Instruction No. 705, solidifying the rights of farmer-beneficiaries to both agricultural lands and residential lots.

From Farmlands to Homelots: How Agrarian Reform Protects Farmers’ Homes

This case revolves around a dispute over a 750-square-meter portion of Lot 5603 in Toledo City, initially owned by Milagros Lebumfacil. The land was placed under the Operation Land Transfer (OLT) program under Presidential Decree No. 27, aiming to emancipate tenant-farmers by transferring land ownership to them. Several lots, including 5603, 5602-B, 5774-5 and 5774-7, were initially awarded to Egmidio Baguio and Josefa Apan, who later waived their rights due to health reasons. Subsequently, the Department of Agrarian Reform (DAR) reallocated these lots to the Vergara and Basalo spouses, who are the respondents in this case. A portion of Lot No. 5603 was awarded to Teodulfo Aviles and Adriano Lumangtad, while the remaining 750-square-meters was awarded to herein respondents as their homelots, being the reallocatees of Lots 5602-B, 5774-5 and 5774-7.

The petitioners, Spouses Calvo, purchased the lands from Lebumfacil despite their coverage under the OLT program. This led to a legal battle when the Calvo spouses filed an illegal detainer complaint against the Vergara and Basalo spouses, seeking their eviction from the 750-square-meter homelots. The central legal question was whether the respondents, as reallocatees of the farmlands, were entitled to the homelots under Letter of Instruction No. 705, which allows for the acquisition of homelots by beneficiaries of Presidential Decree No. 27. The case ultimately hinged on the interpretation of agrarian reform laws and the rights of farmer-beneficiaries.

The Municipal Trial Court initially heard the case before forwarding it to the Provincial Agrarian Reform Adjudication Board (PARAB). The PARAB declared the OLT coverage valid but nullified the reallocation of Lot No. 5602-B to Belibeth Basalo. However, the Department of Agrarian Reform Adjudication Board (DARAB) modified this decision, affirming the validity of the reallocation and declaring the 750-square-meter portion of Lot 5603 as properly covered by OLT as homelots. The DARAB emphasized that the Vergara and Basalo spouses were bona fide farmer-beneficiaries entitled to the homelots.

The Court of Appeals upheld the DARAB’s decision, finding that the disputed area was agricultural and within the coverage of PD 27. The appellate court noted that the petitioners failed to provide sufficient evidence to reclassify the land as residential, such as certifications from the Housing and Land Use Regulatory Board (HLURB) and the DAR Regional Director. The Court of Appeals underscored that mere tax declarations were insufficient to establish the residential status of the land, citing Qua vs. Court of Appeals, G.R. No. 95318, 198 SCRA 236, 242 (1991).

The Supreme Court, in its resolution, addressed the core issue of whether the private respondents were qualified as reallocatees of OLT areas and entitled to a homelot under Letter of Instruction No. 705. The Court emphasized that this was primarily a question of fact, concerning the DARAB’s findings that the respondents were indeed tenant-farmers. Citing Reyes vs. Court of Appeals, G.R. No. 110207, 258 SCRA 651, 658 (1996), the Supreme Court reiterated that it is not the court’s role to review questions of fact in a petition for review under Rule 45 of the Revised Rules of Court, where only questions of law may be raised. The court stated:

there is a question of law when the doubt or difference arises as to what the law is pertaining to a certain state of facts, and there is a question of fact when the doubt arises as to the truth or falsity of alleged facts.

Furthermore, the Supreme Court underscored the principle that findings of fact by administrative agencies, such as the DARAB, are generally accorded great respect due to their specialized knowledge and expertise. It was also emphasized that the DARAB has jurisdiction over all agrarian disputes, including those involving the implementation of agrarian laws like PD 27. Regarding Letter of Instruction No. 705, the court acknowledged its importance in ensuring that farmer-beneficiaries have access to homelots. LOI No. 705 states:

WHEREAS, the homelot actually occupied by the tenant-farmer beneficiary is considered under Section 24 of Republic Act No. 3844, as amended, included in the leasehold and, therefore, is an integral part of his farm and is an indispensable factor in his farm operation;

This reinforces the principle that a homelot is an integral part of the farmer’s livelihood and well-being. The court also considered Memorandum Circular No. 8-80 Series of 1980, which provides guidelines for the reallocation of farmholdings. The guidelines are for “tenant-farmers who refuse to become beneficiaries of Presidential Decree No. 27.” These guidelines ensure that land is distributed to those who will genuinely cultivate it and contribute to agricultural productivity.

By upholding the Court of Appeals’ decision, the Supreme Court affirmed the rights of the Vergara and Basalo spouses to the 750-square-meter homelots. This decision reinforces the intent of agrarian reform laws to provide not only land for farming but also secure housing for farmer-beneficiaries. The ruling serves as a reminder that administrative agencies like the DARAB play a crucial role in resolving agrarian disputes and that their findings of fact are generally respected by the courts. This provides stability and security to farmers who depend on the land for their livelihood. Ultimately, this decision underscores the importance of agrarian reform in promoting social justice and economic development in the Philippines. By ensuring that farmers have access to both farmlands and homelots, the government is helping to create a more equitable and sustainable agricultural sector. This decision reflects the ongoing efforts to address historical inequalities and empower those who work the land.

Below is a table summarizing key arguments and findings in the case:

Issue	Petitioners’ Argument	Respondents’ Argument	Court’s Ruling
Entitlement to Homelots	Respondents are not immediate family members of original tenant-farmers and are not entitled to reallocation.	As reallocatees of farmlands, they are entitled to homelots under LOI 705.	Upheld the entitlement of reallocatees to homelots, emphasizing the intent of agrarian reform laws.
Land Classification	The 750-square-meter portion is residential, not agricultural, and therefore not covered by OLT.	The land is agricultural and covered by PD 27.	The land is agricultural, as petitioners failed to meet the requirements for reclassification.
Validity of Reallocation	Reallocation of farmlots to respondents is null and void.	Reallocation was valid and legal.	The reallocation was valid, reinforcing DARAB’s authority in agrarian matters.

FAQs

What was the key issue in this case?	The central issue was whether the respondents, as reallocatees of farmlands under the Operation Land Transfer (OLT) program, were entitled to a 750-square-meter homelot under Letter of Instruction No. 705. This hinged on the interpretation of agrarian reform laws and the rights of farmer-beneficiaries.
What is Operation Land Transfer (OLT)?	Operation Land Transfer (OLT) is a program under Presidential Decree No. 27 that aims to emancipate tenant-farmers by transferring ownership of the land they till to them. This program is a cornerstone of agrarian reform in the Philippines.
What is Letter of Instruction No. 705?	Letter of Instruction No. 705 allows farmer-beneficiaries of Presidential Decree No. 27 to acquire homelots, regardless of whether those homelots are located within or outside their farmlots. It recognizes the importance of a home for the farmer’s livelihood and well-being.
Who are considered farmer-beneficiaries?	Farmer-beneficiaries are tenants who have been identified and awarded land under the Operation Land Transfer (OLT) program. This includes original beneficiaries and those who have been validly reallocated land due to the original beneficiary’s waiver or inability to cultivate the land.
What role does DARAB play in agrarian disputes?	The Department of Agrarian Reform Adjudication Board (DARAB) has primary jurisdiction over all agrarian disputes, including cases involving the implementation of agrarian laws like PD 27. Its decisions are generally accorded great respect by the courts due to its specialized knowledge and expertise.
What evidence is needed to reclassify agricultural land to residential?	To reclassify agricultural land to residential, one typically needs certifications from the Housing and Land Use Regulatory Board (HLURB) and the DAR Regional Director. These certifications confirm that the land is no longer economically feasible for agricultural use and is suitable for residential purposes.
Why are findings of fact by administrative agencies respected by courts?	Findings of fact by administrative agencies like DARAB are generally respected because these agencies possess specialized knowledge and expertise in their respective fields. Courts often defer to their findings unless there is a clear showing of abuse of discretion or error.
What is the significance of this ruling for farmer-beneficiaries?	This ruling reinforces the rights of farmer-beneficiaries to not only agricultural lands but also to secure housing through homelots. It underscores the government’s commitment to agrarian reform and the protection of farmers’ rights, ensuring they have a place to call home.

In conclusion, the Supreme Court’s decision in Spouses Benny Calvo and Jovita S. Calvo vs. Spouses Bernardito and Angelina Vergara and Spouses Alexberto and Belibeth Basalo reaffirms the importance of agrarian reform in the Philippines and the rights of farmer-beneficiaries to both farmlands and homelots. This case underscores the commitment to social justice and economic development by ensuring that farmers have the resources and security they need to thrive.

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: Spouses Benny Calvo and Jovita S. Calvo vs. Spouses Bernardito and Angelina Vergara and Spouses Alexberto and Belibeth Basalo, G.R. No. 134741, December 19, 2001