DEPARTMENT OF AGRARIAN REFORM v. DEPARTMENT OF EDUCATION

FACTS:

The lands in question, Lot No. 2509 and Lot No. 817-D, were donated by Esteban Jalandoni to respondent DECS (formerly Bureau of Education) in 1921. The lands were subsequently transferred to DECS under Transfer Certificate of Title No. 167175. DECS leased the lands to Anglo Agricultural Corporation for 10 agricultural crop years, and the lease was renewed for another 10 years. In 1993, Eugenio Alpar and others filed a petition for CARP coverage with the Municipal Agrarian Reform Office (MARO) of Escalante. After investigation, MARO sent a notice of coverage to DECS and recommended to the DAR Regional Director to approve the coverage of the landholdings. The DAR Regional Director approved the recommendation, placing the lands under CARP coverage. DECS appealed the decision to the Secretary of Agrarian Reform, who affirmed the decision. DECS then filed a petition for certiorari with the Court of Appeals. The issue to be resolved is whether or not the lands are exempt from the coverage of CARL. The lands were originally private agricultural lands owned by Esteban Jalandoni and continued to be agricultural lands even after they were donated to DECS and leased to Anglo Agricultural Corporation. There is no legislative or presidential act classifying the lands as mineral, forest, residential, commercial or industrial land. Therefore, the lands fall under the classification of lands of the public domain suitable for agriculture.

ISSUES:

  1. Whether the subject properties are exempt from the coverage of Republic Act No. 6657 (CARL).

RULING:

  1. The Supreme Court held that the subject properties are not exempt from the coverage of CARL. The Court noted that the general policy under CARL is to cover as much lands suitable for agriculture as possible. Section 4 of CARL explicitly states that the program covers all public and private agricultural lands, including other lands of the public domain suitable for agriculture. The Court emphasized that the subject lands were formerly private agricultural lands and continued to be agricultural until they were leased to Anglo Agricultural Corporation. There was no legislative or presidential act classifying the lands as mineral, forest, residential, commercial, or industrial land. Therefore, the subject lands fall under the classification of lands of the public domain suitable for agriculture, and are covered by CARL.

PRINCIPLES:

  • The general policy under CARL is to cover as much lands suitable for agriculture as possible.

  • Section 4 of CARL provides for the coverage of all public and private agricultural lands, including other lands of the public domain suitable for agriculture.

  • Lands classified as mineral, forest, residential, commercial, or industrial land are not covered by CARL.

  • Lands devoted to agricultural activity, not classified as mineral, forest, residential, commercial, or industrial land, are considered agricultural lands covered by CARL.