This Court resolves a Petition for Review on Certiorari^[1] under Rule 45 of the 1997 Rules of Civil Procedure, praying that the assailed October 13, 2016 Decision^[2] and July 19, 2017 Resolution^[3] of the Court of Appeals in CA-G.R. SP No. 134933 be reversed and set aside.

The Court of Appeals affirmed the September 27, 2013 Decision^[4] and March 18, 2014 Resolution^[5] of the Office of the President, which had sustained the November 17, 2008 Order^[6] and June 16, 2009 Resolution^[7] of Agrarian Reform Secretary Nasser C. Pangandaman (Agrarian Reform Secretary Pangandaman). Agrarian Reform Secretary Pangandaman denied the Government Service Insurance System's appeal and sustained the October 16, 2006^[8] and December 21, 2006 Orders^[9] of Regional Director Rodolfo T. Inson (Regional Director Inson) of Department of Agrarian Reform Regional Office XI. Regional Director Inson denied the Government Service Insurance System's Petition asking that a piece of agricultural land be excluded from compulsory agrarian reform coverage.

In February 1996, the Metro Davao Agri-Hotel Corporation obtained a P20 million commercial loan from the Government Service Insurance System. This loan was secured by a mortgage over two (2) parcels of land. The first parcel was covered by Transfer Certificate of Title No. T- 234689, while the second, an agricultural land, was covered by Transfer Certificate of Title No. T-54074.^[10]

As the Metro Davao Agri-Hotel Corporation was unable to pay its loan obligations, the Government Service Insurance System foreclosed both properties. After the lapse of the redemption period, ownership of the two (2) properties was consolidated in the Government Service Insurance System.^[11]

On August 10, 2004, Municipal Agrarian Reform Officer Romerico Datoy issued a Notice of Coverage concerning the agricultural land covered by Transfer Certificate of Title No. T-54074. Subsequently, the Department of Agrarian Reform offered to pay the Government Service Insurance System P2,343,370.24 for the property. The latter, in turn, sent a letter to the Provincial Agrarian Reform Office protesting the coverage.^[12]

On May 12, 2006, the Government Service Insurance System filed before the Department of Agrarian Reform Regional Director a Petition asking that the property be excluded from compulsory agrarian reform coverage.^[13]

In his October 16, 2006 Order,^[14] Regional Director Inson denied the Government Service Insurance System's Petition. He further denied its Motion for Reconsideration in his December 21, 2006 Order.^[15]

The Government Service Insurance System appealed the Order, but its appeal was denied by Agrarian Reform Secretary Pangandaman in his November 17, 2008 Order.^[16] It filed a Motion for Reconsideration, which was similarly denied in a June 16, 2009 Resolution.^[17]

The Government Service Insurance System elevated the case to the Office of the President, but its appeal was denied in a September 27, 2013 Decision.^[18] Its subsequent Motion for Reconsideration was denied in a March 18, 2014 Resolution.^[19]

The Government Service Insurance System then filed before the Court of Appeals a Petition for Review. In its October 13, 2016 Decision,^[20] however, the Court of Appeals sustained the rulings of the Office of the President, the Agrarian Reform Secretary, and Regional Director Inson. In its July 19, 2017 Resolution,^[21] the Court of Appeals denied the subsequent Motion for Reconsideration.

Thus, the Government Service Insurance System filed this Petition,^[22] assailing the Court of Appeals Decision.

For this Court's resolution is the issue of whether or not the property covered by Transfer Certificate of Title No. T-54074 may be excluded from compulsory agrarian reform coverage.

Petitioner insists that under Section 39 of Republic Act No. 8291, or The Government Service Insurance System Act of 1997, its properties cannot be utilized for agrarian reform purposes.^[23] It adds that the same provision exempts its properties from agrarian reform coverage.^[24]

Section 39 of Republic Act No. 8291 states:

SECTION 39. Exemption from Tax, Legal Process and Lien. — It is hereby declared to be the policy of the State that the actuarial solvency of the funds of the GSIS shall be preserved and maintained at all times and that contribution rates necessary to sustain the benefits under this Act shall be kept as low as possible in order not to burden the members of the GSIS and their employers. Taxes imposed on the GSIS tend to impair the actuarial solvency of its funds and increase the contribution rate necessary to sustain the benefits of this Act. Accordingly, notwithstanding any laws to the contrary, the GSIS, its assets, revenues including all accruals thereto, and benefits paid, shall be exempt from all taxes, assessments, fees, charges or duties of all kinds. These exemptions shall continue unless expressly and specifically revoked and any assessment against the GSIS as of the approval of this Act are hereby considered paid. Consequently, all laws, ordinances, regulations, issuances, opinions or jurisprudence contrary to or in derogation of this provision are hereby deemed repealed, superseded and rendered ineffective and without legal force and effect.

Moreover, these exemptions shall not be affected by subsequent laws to the contrary unless this section is expressly, specifically and categorically revoked or repealed by law and a provision is enacted to substitute or replace the exemption referred to herein as an essential factor to maintain or protect the solvency of the fund, notwithstanding and independently of the guaranty of the national government to secure such solvency or liability.

The funds and/or the properties referred to herein as well as the benefits, sums or monies corresponding to the benefits under this Act shall be exempt from attachment, garnishment, execution, levy or other processes issued by the courts, quasi-judicial agencies or administrative bodies including Commission on Audit (COA) disallowances and from all financial obligations of the members, including his pecuniary accountability arising from or caused or occasioned by his exercise or performance of his official functions or duties, or incurred relative to or in connection with his position or work except when his monetary liability, contractual or otherwise, is in favor of the GSIS. (Emphasis supplied)

Petitioner's insistence on Republic Act No. 8291's supposed exemption is plain error.

Roman Catholic Archbishop of Caceres v. Secretary of Agrarian Reform^[25] has settled that the exemptions from agrarian reform coverage are contained in "an exclusive list"^[26] which are enumerated under Section 10 of Republic Act No. 6657, otherwise known as the Comprehensive Agrarian Reform Law:

Section 4 of RA 6657 states, "The Comprehensive Agrarian Reform Law of 1988 shall cover, regardless of tenurial arrangement and commodity produced, all public and private agricultural lands as provided in Proclamation No. 131 and Executive Order No. 229, including other lands of the public domain suitable for agriculture," The lands in Archbishop's name are agricultural lands that fall within the scope of the law, and do not fall under the exemptions.

The exemptions under RA 6657 form an exclusive list, as follows:

SEC. 10. Exemptions and Exclusions. —

(a)	Lands actually, directly and exclusively used for parks, wildlife, forest reserves, reforestation, fish sanctuaries and breeding grounds, watersheds and mangroves shall be exempt from the coverage of this Act.
(b)	Private lands actually, directly and exclusively used for prawn farms and fishponds shall be exempt from the coverage of this Act: Provided, That said prawn farms and fishponds have not been distributed and Certificate of Land Ownership Award (CLOA) issued under the Agrarian Reform Program.
	In cases where the fishponds or prawn farms have been subjected to the Comprehensive Agrarian Reform Law, by voluntary offer to sell, or commercial farms deferment or notices of compulsory acquisition, a simple and absolute majority of the actual regular workers or tenants must consent to the exemption within one (1) year from the effectivity of this Act. When the workers or tenants do not agree to this exemption, the fishponds or prawn farms shall be distributed collectively to the worker-beneficiaries or tenants who shall form cooperative or association to manage the same.
	In cases where the fishponds or prawn farms have not been subjected to the Comprehensive Agrarian Reform Law, the consent of the farmworkers shall no longer be necessary; however, the provision of Section 32-A hereof on incentives shall apply.
(c)	Lands actually, directly and exclusively used and found to be necessary for national defense, school sites and campuses, including experimental farm stations operated by public or private schools for educational purposes, seeds and seedlings research and pilot production center, church sites and convents appurtenant thereto, mosque sites and Islamic centers appurtenant thereto, communal burial grounds and cemeteries, penal colonies and penal farms actually worked by the inmates, government and private research and quarantine centers and all lands with eighteen percent (18%) slope and over, except those already developed, shall be exempt from the coverage of this Act. (As amended by R.A. 7881)[27]

In Hospicio de San Jose de Barili, Cebu City v. Department of Agrarian Reform,^[28] this Court emphasized the need for a strict application of the Comprehensive Agrarian Reform Law's exceptions:

To begin with, the terms "charitable purposes" and "charitable organizations" do not appear in Section 10 of the [Comprehensive Agrarian Reform Law]. For its part, Hospicio unduly assumes that charity is integrally wedded to religiosity, despite the fact that there are charitable institutions that are avowedly secular in orientation. We disagree that there is a clear intent or spirit to include properties held by charitable institutions, even those directly utilized for charitable purposes, in the list of exempted properties under the [Comprehensive Agrarian Reform Law]. Section 10 does not include properties which are generally used for charitable purposes, such as orphanages, from the exemption. Not even all properties owned by religious institutions are exempt, save for those places of worship and the convents/Islamic centers appurtenant thereto. Even assuming that the Hospicio were actually owned and operated by the Catholic Church, it still would not be exempted from the [Comprehensive Agrarian Reform Law].

It is axiomatic that where a general rule is established by a statute with exceptions, the Court will not curtail nor add to the latter by implication, and it is a rule that an express exception excludes all others. We cannot simply impute into a statute an exception which the Congress did not incorporate. Moreover, general welfare legislation such as land reform laws is to be construed in favor of the promotion of social justice to ensure the well-being and economic security of the people. Since a broad construction of the provision listing the properties exempted under the [Comprehensive Agrarian Reform Law] would tend to denigrate the aims of agrarian reform, a strict application of these exceptions is in order.^[29] (Citations omitted)

Petitioner's suggestion that an exception exists outside Section 10's exclusive list runs afoul of this Court's pronouncements in Roman Catholic Archbishop of Caceres and Hospicio de San Jose de Barili, Cebu City.

Section 7 of the Comprehensive Agrarian Reform Law is even more specific. It explicitly states that "lands foreclosed by government financial institutions" are subject to agrarian reform:

SECTION 7. Priorities. — The Department of Agrarian Reform (DAR) in coordination with the Presidential Agrarian Reform Council (PARC) shall plan and program the acquisition and distribution of all agricultural lands through a period often (10) years from the effectivity of this Act. Lands shall be acquired and distributed as follows:

Phase One: Rice and corn lands under Presidential Decree No. 27; all idle or abandoned lands; all private lands voluntarily offered by the owners for agrarian reform; all lands foreclosed by government financial institutions; all lands acquired by the Presidential Commission on Good Government (PCGG); and all other lands owned by the government devoted to or suitable for agriculture, which shall be acquired and distributed immediately upon the effectivity of this Act, with the implementation to be completed within a period of not more than four (4) years[.] (Emphasis supplied)

Section 3(m) of Republic Act No. 10149, or the GOCC^[30] Governance Act of 2011, defines government financial institutions:

SECTION 3. Definition of Terms. —

. . . .

(m) Government Financial Institutions (GFIs) refer to financial institutions or corporations in which the government directly or indirectly owns majority of the capital stock and which are either: (1) registered with or directly supervised by the Bangko Sentral ng Pilipinas; or (2) collecting or transacting funds or contributions from the public and places them in financial instruments or assets such as deposits, loans, bonds and equity including, but not limited to, the Government Service Insurance System and the Social Security System. (Emphasis supplied)

Petitioner does not only meet Section 3(m)'s definition; it is even cited as the exemplar of a government financial institution. This, vis-à-vis Section 7 of the Comprehensive Agrarian Reform Law, negates any doubt on its being covered by the Comprehensive Agrarian Reform Law.

WHEREFORE, the Petition is DENIED. The assailed October 13, 2016 Decision and July 19, 2017 Resolution of the Court of Appeals in CA-G.R. SP No. 134933 are AFFIRMED.

SO ORDERED.

Peralta (Chairperson), A. Reyes, Jr., Hernando, and Inting, JJ., concur.

September 9, 2019

NOTICE OF JUDGMENT

Sirs/Mesdames:

Please take notice that on July 24, 2019 a Decision, copy attached hereto, was rendered by the Supreme Court in the above-entitled case, the original of which was received by this Office on September 9, 2019 at 9:22 a.m.

^[2] Id. at 47-60. The Decision was penned by Associate Justice Victoria Isabel A. Paredes, and concurred in by Associate Justices Magdangal M. De Leon and Elihu A. Ybañez of the Seventh Division, Court of Appeals, Manila.

^[3] Id. at 62-63. The Resolution was penned by Associate Justice Victoria Isabel A. Paredes, and concurred in by Associate Justices Magdangal M. De Leon and Elihu A. Ybañez of the Former Seventh Division, Court of Appeals, Manila.

^[4] Id. at 64-71. The Decision was signed by Executive Secretary Paquito N. Ochoa, Jr.

^[5] Id. at 72-73. The Resolution was signed by Executive Secretary Paquito N. Ochoa, Jr.

^[6] Id. at 84-88. The Order was signed by Agrarian Reform Secretary Nasser C. Pangandaman.

^[7] Id. at 89-94. The Resolution was signed by Agrarian Reform Secretary Nasser C. Pangandaman.

^[8] Id. at 75-81.

^[9] Id. at 82-83.

^[10] Id. at 48 and 84.

^[11] Id.

^[12] Id. at 48-49.

^[13] Id. at 49.

^[14] Id. at 75-81.

^[15] Id. at 82-83.

^[16] Id. at 84-88.

^[17] Id. at 89-94.

^[18] Id. at 64-71.

^[19] Id. at 72-73.

^[20] Id. at 47-60.

^[21] Id. at 62-63.

^[22] Id. at 15-37.

^[23] Id. at 20-23.

^[24] Id. at 23-28.

^[25] 565 Phil. 598 (2007) [Per J. Velasco, Jr., Second Division].

^[26] Id. at 610.

^[27] Id. at 610-611.

^[28] 507 Phil. 585 (2005) [Per J. Tinga, Second Division].

^[29] Id. at 601.

^[30] GOCC stands for government-owned or -controlled corporation. See Republic Act No. 10149 (2011).