Natalia Realty, Inc.

and Estate Developer and Investors Corp vs DAR

GR No 103302 August 12, 1993

Facts:
Natalia is the owner of 3 contiguous parcels of land with an area of 120.9793 hectares, 1.3205 hectares
and 2.7080 hectares or a total of 125.0078 hectares, which are covered by TCT No. 31527. Presidential
Proclamation No. 1637 set aside 20,312 hectares of land as townsite areas to absorb the population
overspill in the metropolis which were designated as the Lungsod Silangan Townsite. The Natalia
properties are situated within the areas proclaimed as townsite reservation. Since private landowners
were allowed to develop their properties into low-cost housing subdivisions with the reservation,
petitioner EDIC as developer of Natalia applied for and was granted preliminary approval and location
clearances by the Human Settlements Regulatory Commission, which Natalia thereafter became
Antipolo Hills Subdivision. On June 15 1988, Ra 6657 went to effect. Respondent issed a Notice of
Coverage on the undeveloped portions of Antipolo Hills Subdivision. Natalia and EDIC immediately
registered its objection to the notice of coverage and requested the cancellation of the Notice of
Coverage.

Natalia and EDIC both argued that the properties ceased to be agricultural lands when they were
included in the areas reserved by Presidential Proclamation for the townsite reservation. DAR then
contended that the permits granted were not valid and binding since they did not comply with t he
implementing Standards, Rules and Regulations of PD 957 (The Subdivision and Condominium Buyers
Protective Decree), and that there was no valid conversion of the properties.

Issue:
Whether or not lands not classified for agricultural use, as approved by the Housing and Land Use
Regulatory Board and its agencies prior to June 15, 1988 covered by RA 6657.

Ruling:
No, Sec. 4 of RA 6657 provides that CARL shall cover, regardless of tenurial arrangement and commodity
produced, all public and private agricultural lands. And agricultural lands is referred to as land devoted
to agricultural activity and not classified as mineral, forst, residential, commercial or industrial land.
Thus, the underdeveloped portions of the Antipolo Hills Subdivision cannot be considered as agricultural
lands for this land was intended for residential use. They ceased to be agricultural land by virtue of the
Presidential Proclamation No. 1637.

Luz Farms v. Secretary of DAR

G.R. No. 86889 December 4, 1990
Facts:
On 10 June 1988, RA 6657 was approved by the President of the Philippines, which includes, among
others, the raising of livestock, poultry and swine in its coverage.
Petitioner Luz Farms, a corporation engaged in the livestock and poultry business, avers that it would be
adversely affected by the enforcement of sections 3(b), 11, 13, 16 (d), 17 and 32 of the said law. Hence,
it prayed that the said law be declared unconstitutional. The mentioned sections of the law provies,
among others, the product-sharing plan, including those engaged in livestock and poultry business.
Luz Farms further argued that livestock or poultry raising is not similar with crop or tree farming. That
the land is not the primary resource in this undertaking and represents no more than 5% of the total
investments of commercial livestock and poultry raisers. That the land is incidental but not the principal
factor or consideration in their industry. Hence, it argued that it should not be included in the coverage
of RA 6657 which covers agricultural lands.
Issue: Whether or not certain provisions of RA 6657 is unconstitutional for including in its definition of
Agriculture the livestock and poultyr industry?
Ruling:
The Court held YES.
Looking into the transcript of the Constitutional Commission on the meaning of the word agriculture,
it showed that the framers never intended to include livestock and poultry industry in the coverage of
the constitutionally mandated agrarian reform program of the government.
Further, Commissioner Tadeo pointed out that the reasin why they used the term farmworkers rather
than agricultural workers in the said law is because agricultural workers includes the livestock and
poultry industry, hence, since they do not intend to include the latter, they used farmworkers to have
distinction.
Hence, there is merit on the petitioners argument that the product-sharing plan applied to corporate
farms in the contested provisions is unreasonable for being consficatory and violative of the due
process of aw

Heirs of the Late Herman Rey Santos

vs Court of Appeals
Ponente: Ynares-Santiago

Facts:
A parcel of land in Plaridel, Bulacan was levied on execution by the
MTC of Bulacan in 1989. The land was sold at public auction in 1990
with Santos, [now substituted by his heirs] as the sole bidder.

Santos registered the deed of sale in bulacan in October 1990 after

Exequiel Garcia failed to exercise his right of redemption within the
reglementary period.

In 1992, Garcia filed a petition for injunction and damages with

preliminary injunction with the DARAB, praying that petitioner be
enjoined from preventing private respondent from gathering the mango
fruits. DARAB issued an order allowing the gathering of the mango
fruits and directing that the proceeds thereof be deposited with the
DARAB.

Subsequently, Garcia also filed to redeem his land. This petition was
dismissed. Meanwhile, Pantaleon Antonio filed a motion to intervene
with the DARAB claiming that he is affected in his rights over the
mango trees which he tended for that season. DARAB suspended the
claim of Antonio pending the resolution of the ownership issue.

Later, Antonio filed a motion to withdraw intervenors deposited share

which was granted by DARAB, also recognizing Antonio as the duly
constituted agricultural tenant of the land. This order was affirmed
by the CA. Hence, this petition.

Issue:
(1)Whether the jurisdiction is under PARAD since there is an issue
of ownership.
(2)Whether CA erred in allowing the release of the share without
bond.

Ruling:
Petition is with merit.

(1) Agrarian dispute is under the jurisdiction of DARAB, however in

the case, there is no agrarian dispute since the parties are
contending as to the ownership of the land. And the parties have no
tenurial, leasehold, or any agrarian relations. So DARAB has no
jurisdiction. The issue of the case is ownership which is under the
jurisdiction of the RTC.

(2) As to the claim of Antonio, DARAB has no jurisdiction also because

the issue of who can harvest the mangoes is an ancillary to the main
petition for injunction, so it is dependent on the main case.

CA's decision was reversed and set aside.