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NATALIA REALTY v. DEPARTMENT OF AGRARIAN REFORM

FACTS:

The case involves a petition for certiorari assailing the Notice of Coverage issued by the Department of Agrarian Reform (DAR) over lands owned by Natalia Realty, Inc. (NATALIA) that were already reserved as townsite areas before the enactment of the Comprehensive Agrarian Reform Law of 1988 (CARL).

NATALIA is the owner of three contiguous parcels of land located in Banaba, Antipolo, Rizal. On April 18, 1979, Presidential Proclamation No. 1637 set aside 20,312 hectares of land in Antipolo, San Mateo, and Montalban as townsite areas, which included the NATALIA properties.

NATALIA, with the help of Estate Developers and Investors Corporation (EDIC), developed the properties into the Antipolo Hills Subdivision and obtained the necessary approvals and permits. However, on June 15, 1988, CARL went into effect, and the DAR issued a Notice of Coverage on the undeveloped portions of the Antipolo Hills Subdivision.

NATALIA objected to the Notice of Coverage, and EDIC protested to the DAR Director. In response, members of the Samahan ng Magsasaka sa Bundok Antipolo, Inc. (SAMBA) filed a complaint against NATALIA and EDIC before the DAR Regional Adjudicator, which temporarily restrained the development of the subdivision.

NATALIA and EDIC elevated their cause to the DAR Adjudication Board, but the case was remanded to the Regional Adjudicator. NATALIA then wrote to the Secretary of Agrarian Reform requesting the set aside of the Notice of Coverage, but no action was taken.

Hence, NATALIA and EDIC filed this petition, arguing that the CARL does not cover lands already classified for non-agricultural use.

ISSUES:

  1. Whether lands already classified for residential, commercial, or industrial use prior to the enactment of the Comprehensive Agrarian Reform Law of 1988 (CARL) are covered by R.A. 6657.

  2. Whether the permits granted to the petitioners for the development of the Antipolo Hills Subdivision are valid and binding.

RULING:

  1. The Supreme Court ruled in favor of the petitioners. The Court held that lands that are already classified for residential, commercial, or industrial use prior to the enactment of the CARL are not covered by R.A. 6657. Accordingly, the lands owned by the petitioners, which were part of a townsite area already reserved before the CARL took effect, cannot be subjected to agrarian reform coverage. Moreover, the Court found that the permits granted to the petitioners for the development of the Antipolo Hills Subdivision were valid and binding as they complied with all the requirements of the law.

PRINCIPLES:

  • Lands already classified for residential, commercial, or industrial use prior to the enactment of the CARL are not covered by R.A. 6657.

  • Permits for the development of subdivisions are valid and binding if they comply with all the requirements of the law.