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A Feast for Crows?

: Probing Disaster-Related Land-Grabs


in the Philippines
Jerik Cruz
Graduate Institute for International and Development Studies,
Switzerland
Hansley Juliano
Department of Political Science, Ateneo de Manila University
Enrico La Via
Simbahang Lingkod ng Bayan

This article intends to develop analyses on the occurrence of disaster-related


land- grabbing in the Philippines and how it opens potential challenges to
the recovery and long-term restoration of disaster-stricken communities.
While the phenomenon of land- grabbing is hardly new in the Philippines,
we argue that present patterns of disaster- related land-grabbing are
conditioned by the distinct evolution of Philippine capitalism since the
mid-1980s, the institutional regimes governing access to and use of land
resources, the shifting processes of global economic and environmental
vulnerabilities, and the political dynamics of contention over land and
natural resources. We explore how these factors play out in disaster-stricken
areas in two case studies. First, the extent of supertyphoon Yolandas
aftermath in Sicogon, Iloilo serves as an illustrative example of how
disasters can impinge upon local land struggles in an exclusionary fashion,
with Yolanda facilitating an episode of accumulation by dispossession for
premier tourism development purposes. In contrast, the ongoing campaign
of the rural communities of Casiguran, Aurora against the Aurora Pacific
Economic Zone and Freeport (APECO), reveals how contingencies of natural
disasters, such as typhoon Labuyo, may actually open opportunities for
rural social movements to make significant advances in overcoming
dispossession efforts by entrenched elites in the name of development.
In sum, we explore these negotiated local resistances, historical pathways
of relations between state and capital, institutional arrangements, and
impacts of environmental change, in order to underscore the importance
of reframing questions of land politics amidst rising political, economic and
environmental vulnerability in the Philippines.

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A Feast for Crows?: Probing Disaster-Related Land-Grabs in the Philippines


Jerik Cruz
Graduate Institute for International and Development Studies, Switzerland
Hansley Juliano
Department of Political Science, Ateneo de Manila University
Enrico La Via
Simbahang Lingkod ng Bayan

Close to midnight on August 12, 2013, disaster struck the town of Casiguran, Aurora province in the form of
Tropical Cyclone Labuyo (English: Utor). Boasting winds reaching up to 240km/h, Typhoon Labuyo stood as
the one of the most devastating storms to make landfall in the Philippines that year, second only to Typhoon
Yolanda (English: Haiyan) in November 7, 2013 (Anonymous 2014). The damage inflicted upon the Casiguran
was devastating with almost all reports confirming that 95% of all buildings in the destroyed, and at least PHP18million in farm losses to the municipalitys vibrant coconut industry (Cabreza and Orejas 2013).
Yet even while crippling key segments of Casigurans infrastructural and livelihood systems, Typhoon Labuyo also
proved to be an unforeseen opportunity for the many of the towns residents campaigning for their land rights
against the controversial 12,923-hectare Aurora Pacific Economic Zone and Freeport (APECO). Remarkably,
continued anti-APECO campaigning post-Labuyo resulted in (a) the resignation of APECOs president (Bagong
Aurora 2014), (b) an 86 percent cut of the Freeports official government budget (Orejas 2014), and (c) considerable
postponements in the implementation of APECO subprojects (Ranada 2014). Indeed, at a time when there have
been increasing reports of post-disaster land seizures in the Philippines (Yap 2014), the dynamics of the APECO
episode remains one of the few known cases where community organizations were able to secure strategic advances
in a land dispute following an exceptionally-destructive calamity.
What were the factors and processes that enabled Casiguran residents to make substantial progress in the
achievement of their campaign objectives against APECO after Typhoon Utor? In this discussion paper, we have
undertaken an analysis of the structural-institutional context and the post-disaster contention dynamics of largescale land disputes, which has enabled us to better understand conditions that enabled the exceptional campaign
achievements in the APECO case in the aftermath of Typhoon Labuyo. Drawing from critical political economy,
political ecology, and contentious politics perspectives, we aim to help spur discussion on the political options
available for communities, social movements, and land rights defenders to ensure continued land tenure security
amidst worsening extreme weather events linked to climate change.
The Changing Place of Land and Rising Pressures for Accumulation by Dispossession1
Regardless of the specific mechanisms by which Philippine land-grabs are executed, it is crucial to keep in mind the
broad structural-institutional context in which they are taking place. Indeed, over the past seven years, reports of
displacements of Filipino rural communities from their inhabited lands, and typically accompanied by human rights
abuses such as intimidation, forcible evictions and killings, have dramatically escalated (Manahan et al. 2014: 4041). Though difficult to quantify, various signs including rising numbers of land disputes filed at the Department
of Agrarian Reform Adjudication Board (Bello 2013), and official recognition of heightened human rights abuses
in the countryside from civil society and international watchdogs (Focus on the Global South 2014), the Catholic
1 NOTE: We wish to acknowledge the important Influence that State of Fragmentation: The Philippines in Transition (Pub.:
Focus on the Global South and Friedrich Ebert Stiftung-Philippines, 2014), Standing on Contentious Grounds: Land Grabbing,
Philippine Style in Keeping Land Local: Reclaiming Governance from the Market (Pub.: Focus on the Global South and Land
Research Action Network, 2014), and CARPER Diem: A Socio-Legal Analysis of the State of Comprehensive Agrarian Reform
Program in the Aquino Administration (Pub.: Ateneo Law Journal, Forthcoming) have had on the crafting of this section of this
discussion paper. One of the authors here was also a co-author of these respective publications.
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Church (Tubeza 2013), and the Philippine Commission on Human Rights (Tupaz 2012) all suggest that a more
aggressive drive for commercially-linked land seizures is now under way.
Yet what is distinctive about this latest wave of dispossessions is that a much greater share of them are being driven
by the anticipated commercial returns of large-scale land-use change of agricultural and forest lands. While landgrabbing for the sake of plantation crops such as biofuels, mineral extraction and mega-infrastructure (ex. dam)
purposes continue to pose widespread impacts, the most prominent land acquisitions have arguably come in the
form of real estate-driven efforts for land-use change such as in property development ventures, tourism conversions
and special economic zones (SEZs). According to data from the Philippine Economic Zone Authority, for instance,
the number of Philippine SEZs alone rose by 80.7 percent from June 2008 (166 official SEZs) to December 2013
(300 SEZs) (see Annex II). On the same vein, it should also be noted that most of the prominent land disputes
that have received considerable attention in the media like the 1,125-hectare Hacienda Dolores case in Porac,
Pampanga (with Ayala Land involved), the 8,650-hectare Hacienda Looc in Nasugbu, Batangas (SM Land Inc.), and
the 1,160-hectare Sicogon Island in Iloilo (Ayala Land) (see Annex III) have been characterized by an exceptionally
degree of involvement, if not control, of tourism-affiliated real estate interests over land-acquiring parties.
The immediate momentum for this upsurge in real estate, tourism, and special economic zone-related land
acquisitions owes both to (a) longstanding tendencies among land-based elites to evade the implementation of
the Comprehensive Agrarian Reform Program through land-use conversions (a strategy which has been welldocumented since the 1990s) (Kelly 2003: 170-187), as well as to (b) intensified pressures among land developers to
cash-in on the latest Philippine property market boom, which has been ongoing since 2010 (Bello et al. 2014: 196).
From that year onwards, key economic sectors associated with the property boom, most especially in real estate,
construction and financial intermediation, have outstripped the Philippines national growth rates, reflecting highlyintensified economic activity in these sectors. Based on Philippine Statistical Authority data, while the countrys
gross domestic product expanded by an already-impressive 21.9 percent between the second quarters of 2011 and
2014, those of real estate, construction and financial intermediation grew even further by 27.4 percent, 33.5 percent
and by 24.9 percent respectively. By contrast, the agriculture sector only grew by a paltry 4.9 percent (NSCB 2014).
At the same time, one can trace the structural pressures undergirding the present wave of land-grabs to the
long-term impacts of the Philippines neoliberal restructuring experience since the 1980s on the very contours
of Philippine capitalism. While an extensive presentation of this argument has been done elsewhere2, neoliberal
reform cemented the demise of agriculture as the traditional base of accumulation of the Philippines landed elites,
who, faced with heightened competition from global trade, were pressured to venture increasingly into the real
estate sector an unintended consequence of the 1987 Constitutions prescription that no foreigners can own land
(Bello et al. 2014: 37, 39, 41-42). Under these conditions, the dynamics and motivations of land-based elites have
become more and more distinct from those of the semi-feudalistic hacendero landlords of yore, with the practice
of land brokerage, aggressive spatial expansion and conversion, and the constant mobilization of massive sums of
finance characterizing their accumulative activities (Bello et al. 2014: 54-56).
In the context of a sustained property boom, at stake in this Philippine land rush lies the accruing of megaprofits to property developer and land broker elites; better tax revenues and land rents for local governments; and
the fulfillment of consumer class demands for suburban residences, commercial zones and tourism hubs (Bello
et al. 2014: 196, 209-210). Given that the interests of these distinct actors can so align, the immediate acquisition
of land may be only one element of a broader strategy by which multiple agents of property-based capital are
reshaping national and local institutions (ex. influence over land-use planning bodies), policy frameworks (ex.
pro-private sector SEZ development laws), government units organizational features (ex. privatized planning and
administrative apparatuses), and knowledge structures (ex. analyses by noted economists and think-tanks favoring
real estate expansion over agriculture) all so as to guarantee their expanded accumulation in the present and
future3. At its most extreme, the potential rapprochement of interests between government and private realtors is
2 See: Bello, W., K. Cardenas, J. Cruz, A. Fabros, M. Manahan, C. Militante, J. Purugganan and J.J. Chavez. State of Fragmentation:
The Philippines in Transition. Quezon City: Focus on the Global South, 2014.
3 NOTE: We cite these in particular since these are processes which have already been occurring in the Philippines. Just to
give one powerful example of how privatized planning and administrative apparatuses manifest, the chief marketing and sales
executive of Ayala Land said explicitly in a May 2014 interview in Singapore:
By developing big tracts of land, we become the government; we control and manage everything. We are the mayors and the governors
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facilitating the rise of what sociologist Michael Levien has dubbed the land broker state in which the state has
become a mere land broker for increasingly real-estate driven private capital, in order to achieve the expropriation
of land from small farmers and transferring them to large, and sometimes foreign, corporations for increasingly real
estate-driven projects (Levien 2012: 13).
This does not mean that obstructions do not exist for those seeking to benefit from these land acquisitions and
conversions. Many such barriers to land-based capital accumulation indeed remain: the past uneven geographical
development of Philippine capitalism may have left desirable lands with acute deficits in their infrastructural
environments (ex. an absence of roads, power and other utilities); the rhythms of politics and policy implementation
in the localities at stake may likewise be unpredictable and inconsistent (ex. electoral cycles, changes in bureaucratic
leadership).
But perhaps the most critical barriers, however, concern the limited supply and complexity of formal land markets,
as well as the resistance of smallholders already residing upon lands desired by property developers. As it happens,
multiple and often conflicting property regimes often govern Philippine land resources, and the features of some
laws undergirding some of those regimes (ex. CARPER and the 1987 Constitution) have insulated certain kinds of
rural land from market transactions by default. Soaring transactions costs (ex. capital gains taxes of 6%), and the
lack of a reliable land information system, have further inhibited the titling, registration, and tradability of other
land parcels (Chikiamko and Fabella 2011: 132). This same messiness of Philippines property regimes has normally
proven a fertile ground for conflict with different actors often pressing competing claims to the same plot of land
on the basis of different property regimes, or occasionally, fraudulent and manipulated titles (Chikiamko and Fabella
2011: 133). Not surprisingly, when their land tenure security are put at risk, smallholders physically occupying lands
eyed for acquisition and conversion typically engage in various forms of resistance against losses in their access to
land imposing considerable costs and obstacles on the plans of would-be developers, while depressing whatever
market value the plot of land under dispute may have (Bello et. al 2014: 211-212).
All things considered, the institutional barriers within the Philippines formal land markets have created a situation
where the enormous commercial demand for prime rural land is unlikely to be glutted solely by means of official
market transactions. This is one prime reason why land developers and their allies have increasingly employed extraeconomic (i.e. non-market) processes of accumulation by dispossession against farmers and other smallholders
unwilling or unable to sell their lands. To assimilate non-marketized or difficult-to-acquire territories into the
property development market, accumulators of capital, state officials and land rentiers have increasingly adopted
land-appropriation strategies based on legal manipulation, misinformation machines, national and local horsetrading, supplementary infrastructural development, and frequently, naked force. Somewhat more recently, taking
advantage of the disarray brought about by natural disasters has come into prominence as yet another tactic of landbased elites to overcome their barriers to capital accumulation (Yap 2014).
Disasters and the Question of Land Tenure
Discussing how disasters are received, responded to and subsequently utilized for the purposes of specific interest
groups must take into account historical developments of contentious land issues, considering the limited treatment
of their growing correlation within existing literature. For this purpose, we are assisted by advances done by the field
of political ecology, which responds to emerging questions as to how capital accumulation and the exploitation of
disaster situations is beginning to develop connected dynamics. This requires acknowledging that, in any discussion
about environmental realities, environmental knowledge is unevenly distributed within local societies (Peet and
Richards 2004: 18). Subsequently, it should also question the existing belief that disaster response is largely a matter
of improving scientific prediction, engineering preparedness and the administrative management of hazard, which
renders it as a specialised problem for the advanced research of scientists, engineers and bureaucrats, and so be
appropriated within a discourse of expertise that quarantines disaster in thought as well as in practice (Bankoff
of the communities that we developed and we do not relinquish this responsibility to the government. But because we develop all the
roads, water and sewer systems, and provide infrastructure for power, we manage security, we do garbage collection, we paint every
pedestrian crossing and change every light bulb in the streets the effect of that is how property prices have moved [N]obody on
the political side would want to do anything that would upset whats happening in business, so they tend to be quite supportive of
us. (From: http://www.stproperty.sg/articles-property/singapore-property-news/lack-of-an-urban-planner-a-blessing-for-ayalaland/a/163543)
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2002: 11). With these basic assumptions in mind, we can therefore properly acknowledge how the treatment of the
relationship between climate and agricultural activity (a very important and quite fragile one, at that) can be the
source of existing tensions and potential imbalances in social relations.
Philippine communities capability for adapting to disasters have varied depending on the areas topography, state
of urbanization, as well as the existing socio-economic stability of the households living in the area. Rural areas in
the Philippines have been documented to house 77% of the countrys impoverished households, who rely heavily
on agriculture, fishing and forestry for their livelihood. Around 60 per cent of the occupied land in the country is
informal and 46 per cent of the alienable and disposable lands are untitled. Many people occupy and use public land
without secure tenure. Many of the rural poor are concerned about the lack of land tenure, and there has been an
increasing trend towards people living and having livelihoods in high-risk areas. These include the danger zones
of volcanoes, deforested mountains, riverbeds, low-lying flood plains and coastal areas. Despite their precarious
conditions, these households have little incentive to improve and stabilize their houses (or for that matter their
land security), choosing either to just rebuild after a disaster strikes (Mitchell 2011: 12), or relocate to another
informal area of habitation where there is less risk of being driven off, either by disasters or by human intervention.
Subsequently, these poor households vulnerability is further magnified by their uncontrolled expansion of informal
settlements on public land and hazard-prone areas (29).
Select rural areas in the Philippines have been documented to be capable of adapting to these conditions via
changing their consumption expenditure in response to changes in commodity prices caused by the disaster
[T]he availability of emergency informal transfers from close relatives and aid from the local government in the
form of food basket and house repair materials helped the affected households, most importantly the poor landless
households, to cope with the damages brought about by the typhoon. Furthermore households shifted their
fuel use away from fossil fuels such as liquefied petroleum gas, kerosene, and electricity toward firewood because
of the sharp decrease in the shadow prices of firewood due to the typhoon (Israel and Briones 2014: 9). These
existing socio-economic relations for people living in rural communities are observed to have given them an edge
over some urban households (both wealthy and impoverished ones), whose losses have more adverse impacts on
their livelihoods, daily survival, and future capability to deal with flood hazards (ibid.). Nevertheless, this does not
suggest that rural communities will always have it easier due to their wider resources, as massive disasters can wipe
out large chunks of an environment, leading to loss of land, crop and equipment through landslide and/or flooding
coupled with loss of homes and lives (ibid.).
The question of how people could secure their residence and utilization of the land they currently inhabit, therefore,
becomes the linchpin of the relationship between disasters and land tenure. As we have illustrated in the previous
paragraphs, the situations that develop for many residents and households are not pretty pictures:
Access to land and security of tenure are very often damaged as a result of natural disasters, leaving
people unable to access their land either for production or for housing purposes. The effects can result
from destruction of land tenure records the total or partial destruction of physical evidence of property
boundaries; the disappearance or death of people who have the memory of property boundaries; [and] the
emergence or intensification of conflicts over land tenure that were already present but deteriorated as a
result of the disaster, such as conflicts over inheritance of land rights (Garibay et. al., 2010: v).
This situation is important to be addressed, considering insecure, inequitable and opaque land tenure systems lead
many to live in marginal, hazard-prone areas without the infrastructure required to withstand the natural threats
dictated by geography and climate (Brown & Crawford 2006: 2). It has been argued that for recovery to actually
happen, the following are necessary:
1. Clearly defined and equitable land rights may help to improve planning in areas vulnerable to natural
disasters, as illustrated in the vulnerabilities experienced by the landless farmhands in Divi Seema,
India (2-3);
2. [T]he sooner people can return to their land in a safe environment and with the right tools to rebuild,
the sooner they can recover independence from humanitarian aid, (3); and
3. Recovering and protecting communal and private property rights can lay a solid foundation for
reconstruction, spatial planning, compensation and long-term economic regeneration, the failure of
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which has haunted the recovery process of areas hit by the Asian tsunami such as Aceh and North
Jakarta (6-8).
That being said, the possibility of pursuing such means of inclusive community recovery relies largely on the
political and institutional will of governments to actually take into account the desires and priorities of the affected
communities for restoration and recovery. The moment peoples desire for recovery becomes inimical to emerging
institutional interests towards reshaping the socio-economic makeup of an area, unwelcome impositions are likely
to crop up and conflicts are likely to take place. Exclusivist approaches to disaster response and management,
exhibiting a serious imbalance of power relations within contemporary societies, allows for the isolation of affected
communities in the wake of disaster incidents, rendering them vulnerable not only to the vagaries of nature but
more importantly to the intervention of socio-economic elites which will likely reshape social conditions and access
to resources along more-exclusive and profit-oriented lines.
Disasters and the Dynamics of Land Contention
One of the still-overlooked elements of state-society relations with regards to disaster response and recovery is the
potential conflict over resource usage and realignment, especially in disaster situations where the socio-economic
base of an area is wiped out or in dire need of rehabilitation. After all, governments possess the capacity towards
producing and managing economic capital, through which resources are levied from the population for the benefit
of the consolidation of the states authority and, subsequently, the provision of services supposedly for the benefit of
the public (Bourdieu 1994: 5-6). Through governments capacity to control and mobilize vast amounts of resources
to achieve its specific concerns (and private capitals evolving ability to do the same), it is therefore possible to engage
in the processes of creative destruction, where formerly-unspoilt areas of nature (initially termed first nature) is
intervened upon, utilized, exploited and further modified into new configurations of geography, topography and
wildlife (subsequently termed second nature). These leads to changes in the natural material world, where [t]he
geographic landscape of capital accumulation is perpetually evolving, largely under the impulsion of the speculative
needs of further accumulation (including land speculation) and only secondarily in relation to the needs of people
(Harvey 2010: 184-185).
The increasingly-contentious collusion between governments and private investments for the purpose of land usage
and reallocation are also being reproduced in developing countries. Disasters, for their part, have actually expedited
and facilitated the land broker state-private capital speculator relationship, considering the displacement of
large numbers of people without clearly defined land ownership can enable private and government land grabs, as
illustrated in the cases of the Phang Nga people of Ba Tung Wah, Thailand (whose lands are being sold off by their
government to the German Embassy in Bangkok), Indias Tamil Nadu government using the disaster to plan to
redevelop the area in favour of tourism after the 2004 Asian tsunami, (Brown & Crawford 2006: 4). The internal
and social dynamics of such public-private partnerships were vividly illustrated by Naomi Kleins reportage on how
the government of the United States of America was able to practice predatory forms of resource allocation via the
close cooperation of state apparatuses and outsourced private firms. In The Shock Doctrine (2007), she documented
how the U.S. governments cooperation with private military contractors (PMCs) allowed for the virtual practice
of apartheid in occupied territories in Iraq, labelled green zones where almost all aspects of life were controlled
by private-company services deputized by the U.S. government. The experiences and practices utilized here (which
involved total social control and the utilization of maximum force to create conditions of precarity) were later
transplanted wholesale during the attempts to reconstruct areas in America hit by Hurricane Katrina in 2005. The
eponymous shock doctrine was explicitly practiced by what is argued to be a hollowed-out government (298)
cooperating with the corporate sector in intervening and reshaping the social structure of disaster-stricken societies,
encountering little to no resistance specifically due to the vulnerability of target communities.
These pressures, in more ways than one, contribute to the grim utilization of land and its subsequent negative
backlashes to the Philippine rural economy for the past few decades, where it traditional farming households
have barely kept up with low productivity and even lower incomes. Land speculation and foreign investments are
adding upward pressure to land prices and to entice farmers to lease their lands, some of them losing their CAR
(comprehensive agrarian reform)-awarded lands in the process. The problems in industry prevent the sector
from absorbing excess rural labor, making them suffer the blight of urban poverty (Bello et. al. 2014: 125). The
multiple cases of land-grabbing in the Philippines affecting the localities of Casiguran, Aurora, Caluya Island in
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Antique, Porac, Pampanga, Nasugbu, Batangas, Plaridel, Bulacan and Sicogon Island in Iloilo4 are mostly cases of
rural economies being forced by multiple pressures from state and big capital to re-orient towards more serviceoriented and urbanized economies, at the cost of endangering existing socio-economic relationships on the ground.
Yet, all the same, we must remember the classic observation [w]here there is power, there is resistance, and yet,
or rather, consequently, this resistance is never in a position of exteriority in relation to power (Foucault 1990:
94-95). In the same fashion that governments and private capital have shaped the material conditions by which
communities may be forced to subsist, communities and households nonetheless have an incentive (and subsequently,
mechanisms) by which they can shape and pressure these forces to respond to their immediate concerns. Insofar
as these sections of society have enough resources to deploy in their contention over their tenure and usage of the
land, competition over space and resources may not necessarily be as one-sided as previously thought. The interplay
between disaster capitalism and land use conflict thus must be explicitly spelled out.

Fig. 1. Interaction Dynamics of Resources and Institutions within Development Projects


The initial framework we use in this study is illustrated in Fig. 1, where the relationship between land and population
is to be rendered stable (i.e. conducive to the populations demand and usage) insofar as the influence of government
institutions and private developers in land utilization does not impinge on the residents concerns. Most residents
and/or households concerns centre on whether the changes to be made on the land-scape will translate towards
the building of public infrastructure which will afford these residents social and spatial mobility, which could
facilitate the employment and transformation of the population into a productive workforce. The accomplishment
of these priorities, on baseline, will allow for the pursuit of a private development project even if it changes the
socio-economic base of a locality. This is almost always made possible by [t]he involvement of local politicians
mayors and governors in particular in the process of land and labour management, with the ability of such
figures to act as go-betweens in the entry of foreign capital to their jurisdictions has enabled them to entrench their
political power through the financial benefits accompanying such development and facilitates the discursive selfrepresentation of power holders as the intermediaries in bringing the benefits of rapid industrialization to their
people (Kelly 2000: 161). This nonetheless acknowledges that the power of state structures pursuing urbanization
can (and almost always will) coordinate with the priorities of private investors, and may attempt to transform the
population and land towards more urbanized economies which may or may not entirely be done with their consent.
The situation, however, can potentially change when disasters strike a specific location.
Fig. 2, on the other hand, intends to illustrate the potential rearrangement of forces in light of the advent of disaster
situations. Depending on which of the socio-economic components in a specific area (as well as the institutions
4 Details regarding these land-grabbing cases in the Philippines are provided in Annex III.
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involved in the development of the area) is hit, the conversion of land, resources, governance structures and socioeconomic relationships towards less-inclusive forms of development may be sped up or slowed down by community/
population resistances. The interplay of disaster and political opportunity is best illustrated in in the subsequent
figures which attempt to approximate what is happening in the municipalities of Casiguran, Aurora.

Fig. 2. Interaction Dynamics of Society and Institutions with Disasters


For its part, Casigurans resident population (Fig. 3) is able to resist the intervention of public structures and
private capital due to the areas wide land mass, diverse population, diversified workforce (some rural economy,
others gravitating to relative urbanization), and established infrastructure, which allows it to be less-receptive to
imposed urbanization efforts precisely because its imposition is non-inclusive and is economically unfeasible. The
municipality of Casigurans wide land mass (currently pegged at 71,543 hectares) allows for the dispersal of its
diverse population into different forms of economic activity, with a balanced number of their people continuing to
sustain and cultivate traditional farming, fishing and indigenous activities while allowing more of their numbers to
participate in more modernized forms of employment and income-generation.
As will be illustrated further in our discussion of the case of Casiguran, a development project that intervenes in the
status quo of a locality will largely be received/opposed based on the economic feasibility and the actual capacity of
the project to integrate the existing economic systems/relationships in that locality. The imposition of the project,
despite potential opposition of the existing society in the locality, is dependent on the access of the locality to the
implementing body/structure/institution and their relative social balance/amicability with the local community.
The addition of a disaster in the equation will depend on which side is further hit or damaged by the disaster, and
which of these competing sides manage to recoup and reorganizes their forces and resources to validate their claim
on the reconstruction of the locality. As this study will show, the fortuitous damages that APECO sustained (in
contrast to the damages endured by the people of Casiguran) in the aftermath of Typhoon Labuyo, coupled with
an existing network of social forces and governance structures that oppose the APECO project, accounts for the
continuing failure of APECO to fully exploit disaster capitalism while allowing the communities in Casiguran to
engage in a sustained counterattack to defend their holding rights to their land and territories.

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Fig. 3. Casiguran, Aurora Situation Map


The Politics of Land Struggles and Disasters in Casiguran
The case of the Angara political dynasty, the main proponents of the APECO Freeport, illustrates the intersection of
heightened disaster risk, real-estate accumulation, and special economic zone-related land-grabbing. In the APECO
episode, we argue, the Angara clan occupies dual roles as (a) land-brokers of cheap land for real-estate developers
and (b) property developers that will lead the development of Casiguran into a commercial, industrial, and tourist
center. In the first capacity, the Angaras, through the state-sanctioned powers of APECO, are aiming to make the
municipality conducive to private-sector led development, which would entail, acquiring cheap land, implementing
business-friendly policies, neutralizing local opposition to land acquisitions, improving the built infrastructure
of the area (ex. roads, power, water, sanitation, ports). Yet at the same time, the Angara family is also positioning
itself to directly reap the benefits of a tourist and real-estate boom in Casiguran as indicated in their control
over many of Auroras local government units and dominant presence in key provincial markets. It seems, in other
words, that the Angaras are collectively functioning as the middlemen and buyers of land at once both brokers
and developers of property in Aurora.
The Aurora Pacific Economic Zone and Freeport Authority covers 12,923 hectares, arguably making it one of the
biggest ongoing attempts at land-grabbing in the Philippines today. Moreover, occupying key posts in the local
government (Gov. Bellaflor Angara-Castillo), the Senate (Sen. Edgardo Angara), and Congress (Rep. Juan Edgardo
Angara) at the time of APECOs creation by law in 2007 (via R.A. 9700) and immense expansion in 2010 (R.A.
10083), the role of the Angara political dynasty in the Freeports establishment and implementation cannot be
understated. Indeed, they were chiefly responsible for the railroaded passage of both APECO laws; they constituted
the majority of APECOs board of directors, and have likewise served since the projects inception as its most vocal
and recognizable political champions (Task Force Anti-APECO 2013).
However, APECOs presence in Casiguran must also be understood as part of the broader process of what Aurorabased civil society organizations call the Angarafication of Aurora (Bataris 2013). This Angarafication is already
evident in the experience of what the Angara family has achieved in the transformation of Baler, the provincial capital
of Aurora province: namely, how they have driven a sweeping tourism and property development transformation in
Baler and how they have been one of the biggest beneficiaries of boom in that municipality.
For all their public image as builders of Aurora, the Angara family remains strategically positioned to directly reap
some of the greatest benefits of the real estate and tourism booms now buffeting Aurora province. In 2010, available
documentation reveals that members of the family and their land companies (ex. Sea and Sierra Vista, Inc., and GMA
D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

Farms Inc.) owned no less than 48 distinct property lots in Brgys. Sabang and Zabali in Baler, which have since been
developed into some of Auroras premier private resorts such as the Costa Pacific, Bahia de Baler, Bays Inn Baler,
and Dicasalarin Cove (see Annex IV). More properties still have been documented acquired by family members,
particularly former Senator Angara, in the neighboring towns of San Luis and Maria Aurora. In addition, according
to the church-based Bataris Formation Center based in Baler, members of the Angara clan have also been reputed
to own or have acquired a significant presence in provincial banking (Aurora Bank), transport companies (Genesis
Transport Service Inc., Aurora Bus), schools (Aurora Polytechnic College, Aurora State College of Technology), and
agricultural processing complexes. (Bataris 2013). Provided this commanding position in Auroras economy, the
Angara family has received tremendous direct and indirect returns from increased commercial, financial, vehicular,
and human flows into Aurora province over the past few years.
These present condition of Baler illustrate how the Angaras are also likely to benefit from the SEZ-led development
of Casiguran. Yet the Angaras can only become the Builders of Casiguran, by seizing already-owned land for a
cheap value. Given the lack of robust land markets in Aurora province, and the unwillingness of a considerable
share of Casigurans residents to sell their lands, it would be tremendously difficult for the Angaras to acquire land
and pave way for massive property development without the state-sanctioned powers of APECO. This was most
likely why the Angaras were compelled to mobilize their formidable political and social capital behind the creation
of a Freeport with special powers of expropriation and control over land usages, which can effectively act as an
instrument for generating the enabling conditions of high-level capital accumulation. Their efforts, in earlier years
of APECOs operationalization, appeared to have been bearing fruit: in then-Governor Bellafor Angara-Castillos
words, APECOs creation resulted in a real estate boom in Casiguran, with a tide of property purchases and
tourism developments by regional businessmen driving the towns land parcel prices up by 300% between 2009 and
2011 (de Asis 2011).

It is through APECO that the Angaras exercise their role as the land-brokers of Casiguran. On the level of policy
and laws, APECO is attempting to attract domestic and foreign investors through the implementation of economic
policies and laws that are more free-market-oriented than the Philippines national laws. For this reason, APECO
claims to offer investor various investment incentives: (a) income tax holidays, (b) net operating loss carry over,
(c) raw materials incentives, among others (APECO, accessed Feb. 8, 2015). Yet what APECO can truly offer to
investors would be undervalued land. According to R.A. 10083, APECO has the power to acquire either by purchase,
negotiation, or condemnation proceedings any private land within or adjacent to the Aurora Ecozone (Republic
Act 10083, 2010). This effectively vests APECO with the power to expropriate land from the Agta people of the
San Ildefenso Peninsula as well as other long-time settlers who have resided in and cultivated the majority of the
territory spanned by the economic zone. In granting the Freeport these powers, R.A. 10083 essentially disregards
the tenurial rights of the farmers, fisherfolks, and indigenous people of Casiguran as well as numerous asset reform
laws that have been ratified to protect those rights the CARPER Law, the IPRA Act, and the Fisheries Code
(PAFID 2011: 9).
With such legal powers, APECO has combined both coercive and economic means to acquire land. One of APECOs
most common tactics is to compel farmers, fisherfolks, and indigenous people to comply with the projects development
plans and accept P45,000 per hectare or be forcefully evicted from their lands. In this, it is important to bear in mind
that according to APECOs own Senate testimonies the market cap for rice land is valued at around P200-thousand
per hectare five times more than APECOs offer (Philippine Senate, Oct. 2011, 8). Other times, APECO has offered
financial aid (employment and dole-outs) in exchange for support to the ecozone. These promises, though usually
unfulfilled, have been fairly effective in dividing the community and weakening opposition.
It has been argued that natural disasters can provide a window for the land-grabbers to seize the land from
smallholders. As earlier said, APECO was unable to take advantage of Typhoon Labuyo. In August 12 2013, Casiguran
was hit by the typhoon hurting at least 32 people, destroying 453 houses, and damaging 2,824 structures in the
process (Cabreza and Orejas 2013). It would have been the perfect time for APECO to take physical possession of
the territory it was claiming and gain significantly leverage in inducing residents to cede their lands in exchange for
financial support.
Yet there was no such real attempt from APECO. In Table 1, we enumerate the factors that led to the failure of
APECO to take advantage of Typhoon Labuyo.
D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

TABLE 1: Factors that led to the failure of APECO to take advantage of Typhoon Labuyo
Pre-Disaster Factors
Post-Disaster Outcomes
ALTERNATIVE SOURCES OF POST-DISASTER 1: The damage caused by Typhon Labuyo was partly
AID AND SUPPORT.
offset by the speedy and substantive support given by the
national Taskforce and the Church of Infanta. However,
The local opposition to APECO is strongly supported it was vital in providing another channel for community
by the Church and other national groups. Church and members to circumvent the political interference by
NGO relief activities proved vital in the rapid recovery APECO supporters with the delivery of aid, as well as
of Casiguran and resumption of campaigning efforts the sluggishness of government response.
after Labuyo so as to minimize the vulnerability of
residents to APECO offers.
DIFFUSED AND DIFFERENTIATED NATURE OF 2: Not all sectors and communities were hit as hard by
LOCAL OPPOSITION.
the typhoon. Some of the groups were badly hit, while
others were relatively unharmed and therefore able
The local Taskforce is composed of a variety of sectors to provide aid and support. Worst-hit were upland/
(coconut farmers, rice farmers, indigenous people, and coconut farmers, while indigenous peoples, who are
fisherfolks) that are spread out by land and sea over highly adapted to extreme weather events and did not
12,923 hectares. The diffused nature of local opposition rely on long-term crops for their livelihoods, were able
makes it difficult to defeat in one stroke.
to recover quickly.
APECO UNPREPAREDNESS FOR DISASTERS.
3: The administration building of APECO as well as
several other projects was wrecked by the disaster. These
APECO was unprepared for coping with disasters. No projects remain unrepaired, almost two years later.
feasibility studies to inform them of which areas were
disaster-prone were conducted a feature which has
been characteristic of almost all of their initiatives.
ESTABLISHED CONTROVERSY PERCEPTIONS 4: APECOs ability to expand and act crippled by lack
RESULTING
FROM
PAST
ANTI-APECO of private sector and cohesive government support.
CAMPAIGN EFFORTS.
They have to rely on limited public funds. The longdeclining prospects for APECO, heightened by the
Already-diminishing investor confidence in APECO disaster, triggered a reported exodus of personnel, and
because of its perceived financial unviability due to its negligence of Utor-damaged facilities.
distance from Manila and vulnerability to disasters.
COMMUNITY
PREPAREDNESS
AND 5: Losses and fatalities were mitigated by the effective
ADAPTEDNESS FOR DISASTERS.
response of the residents. This contrasts with the record
of APECO, which has not been effectively adapted to
Effective municipal disaster risk policies (ex. regular the environmental vulnerabilities of Casiguran since
storm drills) as well as considerable experience among its creation, and has failed to learn from prior storm
the locals in dealing with natural disasters.
experiences.
Since 2013, the local communities of Casiguran have gradually been able to recover from the onslaught of Typhoon
Labuyo. APECO, on the other hand, is still reeling from the disasters impacts with its administration building and
many of its other projects still unrepaired. Even more importantly, its credibility as a project has been irreparably
damaged. Indeed, one of the most cited and convincing reasons in the Senate Budget deliberations of 2014 why
APECOs 2015 budget should be reduced was because of the wreckage that it suffered during the disaster. It was
contended that the impact of Typhoon Labuyo validated how Casiguran is too environmentally-risky for the kinds
of investment and property projects envisioned by the ecozone (Alpasa 2014). The resulting budget cuts have further
paralyzed the megaproject by severely limiting its access to public funds: it was set to receive only P40-million instead
of its proposed P251-million budget for 2015. In this manner, the APECO case illustrates the possibility that disasters
can function as a double-edged sword for would-be land-grabbers. They can provide a window of opportunity for
gaining the advantage in land disputes, yet can also backfire, as seen in the Casiguran experience.

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

On the whole, APECO remains but a microcosm of a form of land-grabbing that is becoming increasingly prevalent
in the Philippines: one that is propagated by rent-seeking political actors like the Angaras who function as both
land-broker and property developers. As the land-broker, the Angaras have dispersed obstacles to land-based capital
accumulation such as residents who have resided in the land for years. As property developers, they remain
strategically positioned to benefit from this commodification of rural land for private sector-led development.
While elsewhere natural disasters have been taken advantage of to acquire land amidst the disorientation of local
communities, the Typhoon Labuyo and APECO example suggest that this remains only a contingent, and in some
cases, a high-risk undertaking that can boomerang unexpectedly against the forces of dispossession.
About the Authors
Jerik Cruz was a researcher and advocacy communications specialist focused on issues of development, land/
environmental rights, and democratization in Southeast Asia. He has been affiliated with the Bangkok-based
policy research organization Focus on the Global South since graduation (with honors) from the Ateneo de Manila
University in 2009, and is a co-author of Focus-Philippines forthcoming book entitled State of Fragmentation: The
Philippines in Transition (2014). He is now pursuing a Masters with full scholarship at the Graduate Institute of
International and Development Studies in Geneva, Switzerland this 2014.
Hansley Juliano currently serves as a part-time lecturer in the Department of Political Science, Ateneo de Manila
University. He received his Masters of Arts in Political Science (major in Global Politics) last 2013 from the same
university, and was awarded the 2014 Outstanding Graduate Thesis Award for his research on Philippine leftist
political parties. Among other commitments, he is also engaged as a researcher-writer for Task Force Anti-APECO,
a national coalition of peoples organizations and civil society groups protesting land rights violations in Casiguran,
Aurora. His research interests include socio-political movements, political and economic development, issues of
precarious sectors and methods in comparative political research.
Enrico La Via is currently the Political Officer of Simbahang Lingkod ng Bayan, the socio-political arm of the
Philippine Jesuits. He is also an officer of Taskforce Anti-APECO, a national coalition of peoples organizations, civil
society groups, and university students protesting land rights violations by the in Casiguran Aurora. He received his
Bachelor of Arts in Philosophy (with honors) from Ateneo de Manila University in 2014 where he first participated
in the APECO issue. His other involvements include civic education, labor rights, and good governance reforms.

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

ANNEX I. Bibliography
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Aurora Pacific Economic Zone (APECO). Incentives.Aurora Pacific Ecozone and Freeport Authority,
accessed February 8, 2015. http://www.aurorapacific.com.ph/sub_page.php?s_page=Incentives.
Bataris Formation Center. Pork Barrel Presentation on the Angaras and Pork Barrel. Baler, 2013.
Bankoff, Greg. Cultures of Disaster: Society and natural hazard in the Philippines. New York:
RoutledgeCurzon, 2002.
Bello, Walden. Waterloo for Agrarian Reform? Philippine Daily Inquirer, September 16, 2013.
Accessed October 30, 2014. http://opinion.inquirer.net/61273/waterloo-for-agrarian-reform
Bello, W., K. Cardenas, J. Cruz, A. Fabros, M. Manahan, C. Militante, J. Purugganan and J.J. Chavez.
State of Fragmentation: The Philippines in Transition. Quezon City: Focus on the Global South, 2014.
Bourdieu, Pierre. Rethinking the State: Genesis and Structure of the Bureaucratic Field, in
Sociological Theory, Vol. 12, No. 1, March 1994. 1-18.
Brown, Oli and Alec Crawford. Addressing Land Ownership after Natural Disasters: An Agency Survey.
Winnipeg: International Institute for Sustainable Development (IISD), 2006.
Cabreza, Vincent and Tonette Orejas. Typhoons test Aurora towns resilience. Philippine Daily
Inquirer. August 20, 2013. http://newsinfo.inquirer.net/470473/typhoons-test-aurora-townsresilience.
Chikiamko, Calixto and Raul Fabella. Property Rights Reform in the Philippines: The Residential
Free Patent Act. Built on Dreams, Grounded in Reality: Economic Policy Reform in the Philippines. Asia
Foundation, 2011.
De Asis, Jason. Aurora ecozone site booming in real estate Bagong Aurora, 30 January 2011.
Editorial. Quo Vadis, APECO? Bagong Aurora, 12 January 2014. Accessed October 30, 2014.
http://bagongaurorawebsitengbayan.wordpress.com/editorial-news/quo-vadis-apeco/.
Foucault, Michel. The History of Sexuality Vol. 1: An Introduction. New York: Vintage, 1990.
Garibay, A. H., P. de Wit, L. Eleazar, F. J. Bucheli, S. Norfolk, R. S. Mena and S. Shafi. Land Tenure
and Natural Disasters: Addressing Land Tenure in Countries Prone to Natural Disasters. Rome: Food and
Agriculture Organization (FAO), United Nations, 2010.

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Harvey, David. The Enigma of Capital and the Crises of Capitalism. London: Profile Books, 2010.
Israel, Danilo C. and Roehlano M. Briones. Disasters, Poverty, and Coping Strategies: The Framework and
Empirical Evidence from Micro/Household Data - Philippine Case. DISCUSSION PAPER SERIES NO.
2014-06. Makati: Philippine Institute for Development Studies (PIDS), 2014.
Kelly, Phillip. Landscapes of Globalization: Human geographies of economic change in the
Philippines. London: Routledge, 2000.
___________. Urbanization and the politics of land in the Manila region. The Annals of the
American Academy of Political and Social Science, (Nov. 2003): 170-187.
Klein, Naomi. The Shock Doctrine: The Rise of Disaster Capitalism. New York: Metropolitan Books,
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Levien, Michael. The Land Question: Special Economic Zones and the Political Economy of
Disposession in India. Paper presented at the International Conference on Global Land Grabbing,
University of Sussex, United Kingdom, April 6-8, 2011.
____________. The Politics of Dispossession: Theorizing Indias Land Wars. Paper presented at
the International Conference on Global Land Grabbing II, Land Deals Politics Initiative (LDPI)
and the Department of Development Sociology at Cornell University, Ithaca, NY. October 17-19,
2012.
Orejas, Tonette. Govt wont shut down Aurora ecozone. Philippine Daily Inquirer, 13 January 2014.
Accessed Oct. 30, 2014. http://newsinfo.inquirer.net/563303/govt-wont-shut-down-auroraecozone
Manahan, Mary Ann et. al. Standing on Contentious Grounds: Land-Grabbing, Philippine Style,
Keeping Land Local: Reclaiming Governance from the Market. LRAN Briefing Paper Series No. 3, Focus on
the Global South and Land Research Action Network, October 2014.
____________________. Justice for Ka Melon and his family! Stop the attacks on peasants and
peasant leaders! Petition, 2014. Accessed Oct. 30, 2014. http://focusweb.org/content/justice-kamelon-and-his-family-stop-attack-peasants-and-peasant-leaders
Mitchell, David. Assessing and Responding to Land Tenure Issues in Disaster Risk Management: Training
Manual. Rome: Food and Agricultural Organization (FAO), 2011.
Peet, Richard and Michael Watts, eds. Liberation Ecologies: Environment, Development, Social Movements
(2nd ed.). London: Routledge, 2004.
Philippine Association for Intercultural Development. Impacts of Special Economic Zones on
Indigenous Peoples in the Philippines. Quezon City: PAFID, 2011.
Philippine Statistics Authority. Gross Income and Gross Domestic Product by Expenditure Shares
2nd Qtr 2008- 4th Qtr 2014. National Statistical Coordinating Board, Economic Accounts. Accessed
25 Sept. 2014. http://www.nscb.gov.ph/secstat/d_accounts.asp.

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Ranada, Pia. A small-time Angara faces the skeletons of APECO. Rappler, 12 April 2014.
Accessed Oct. 30, 2014. http://www.rappler.com/newsbreak/investigative/55253-apeco-angaraskeletons-promises
Republic of the Philippines. Senate Committee on Finance Hearing Transcripts. Transcripts of
hearing, Philippine Senate, October 2011.
Task Force Anti-APECO. Walang Daang Matuwid sa APECO: An Appeal to Stop the Serial
Abuses of Aurora by the Angara-Sponsored/Controlled APECO. Petition, 2013.
Tubeza, Philip. Revamp DAR, 78 bishops urge Aquino. Philippine Daily Inquirer, February 2nd, 2013.
Accessed Oct. 30, 2014. http://newsinfo.inquirer.net/351161/revamp-dar-78-bishops-urge-aquino
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Accessed Oct. 30, 2014. http://www.rappler.com/move-ph/15226-are-environmental-activiststargeted-for-killing
Yap, Dj. Land-grabbing now prevails in Yolanda disaster areas rights groups. Philippine Daily
Inquirer, 11 December 2013. Accessed Oct. 30, 2014. http://newsinfo.inquirer.net/544803/landgrabbing-now-prevails-in-yolanda-disaster-areas-right-groups

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

ANNEX II. Philippine Special Economic Zones 2008 and 2013

Source:

Philippine Economic Zone Authority

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

ANNEX III: Profiles of Selected Large-scale Land-Grabs in the Philippines


CASE

SIZE AND
LOCATION

AGENTS
INVOLVED

RATIONALE

APECO (Aurora
Pacific Economic
Zone and Freeport
Authority)

12,923-hectares /
Casiguran, Aurora
province

Angara political
dynasty; APECO
administration;
investors

Creation of Freeport
/ Special Economic
Zone

CALUYA

Up to 3,095 hectares
/ Caluya Island,
Antique

Semirara Mining
Corp.; Javier family;
local government
officials

Tourism
development and
expansion of coal
mining

HACIENDA
DOLORES

1,125-hectares /
Porac, Pampanga

Ayala land; Leonio


Land; FL Properties
and Management
Corporation

HAMILO COAST /
PICO DE LORO

Up to 8,650-hectares
/ Nasugbu, Batangas

LUMINA HOMES

12.47 hectares /
Plaridel, Bulacan

SM Land Inc.;
Manila Southcoast
Development
Corporation; FilEstate
Lumina Homes of
Vista Land; Villar
family

Establishment of
Alviera, a large-scale
mixed-use
community and
business district
Coastal tourism
zone, residential
community and
environmental
reserve
Establishment of
residential
subdivision

SIDECO (Sicogon
Island Development
Corporation)

1,160-hectares /
Sicogon Island,
Iloilo

Ayala land; Sarroza


family; SIDECO
administration

Establishment of
Sicogon Island
Resort Complex

Source: Various Sources

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

ALLEGED
COMMUNITY
IMPACTS
Harassment and
intimidation, illegal
land conversions,
loss of land tenure
security,
environmental
degradation
Eviction from
homes, demolitions,
environmental
degradation, loss of
fishing grounds,
harassment and
detainment of
residents
Eviction from
homes, demolitions,
harassment and
intimidation, killings
Harassment and
intimidation, loss of
land tenure security,
illegal land
conversions
Illegal land
conversions;
flooding of
farmlands
Eviction from
homes, harassment
and intimidation, loss
of land tenure
security

ANNEX IV: Documented Properties of Angara Clan in Baler, San Luis, and Maria Aurora
Aurora Province, 2010
REAL ESTATE PROPERTIES OF THE ANGARA FAMILY

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

IMAGES OF ANGARA PROPERTIES IN BALER


Dicasalarin Cove and Bay which is owned by GMA Inc.

Picture on the right: Former Senator Edgardo Angara escorting people around Dicasalarin.

Costa Pacifica

Costa Pacifica is the only four star hotel in Baler which has become a surfing hotspot in the country. Owned by the
Angara family (Sea and Sierra Vista, Inc.) the hotel, according to residents, is fully booked during summer.

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

ANNEX V: APECO Infrastructure Post-Typhoon Labuyo and Angara-owned


Developments in Baler
POST-LABUYO IMPACTS ON APECO INFRASTRUCTURE
Casiguran International Airport- PHP 486-million (2014)



Airport being used as a rice dryer by farmers. No commercial planes have landed in the airstrip.

APECO Administration Building- More than PHP 61.7-million (2013 and 2014)
2013

Administration building destroyed by the typhoon. Almost two years later, APECO has yet to repair the building.

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

Mariculture Project of APECO- P10-Million (2013)

Fish cage project of APECO destroyed by the Typhoon.

Baler-Casiguran Highway- PHP 4.001-billion (2012 and 2014)

Many parts of the Baler-Casiguran highway remain unpaved.

D R A F T : D O N O T C O P Y, C I T E O R Q U O T E

10