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MENDOZA, Roland Joseph C.

/ 2AA/ 2015-087212
Primer on R.A. 6557 or the Comprehensive Agrarian Reform Law:
Principles
A. Section 2, R.A. 6557

a. What is the main purpose of the Comprehensive Agrarian Reform Program?


- The welfare of the landless farmworkers will receive the highest
consideration to promote social justice and to move the nation toward
sound rural development and industrialization, and the establishment of
owner cultivatorship of economic-size farms as the basis of Philippine
agriculture.

b. How does the Comprehensive Agrarian Law plan to achieve this end?
- To this end, a more equitable distribution and ownership of land, with due
regard to the rights of landowners to just compensation and to the
ecological needs of the nation, shall be undertaken to provide farmers and
farmworkers with the opportunity to enhance their dignity and improve the
quality of their lives through greater productivity of agricultural lands.

B. Sections 4-8, Article XIII of the 1987 Constitution

c. Where is the agrarian reform founded?


- The agrarian reform is founded on the right of farmers and regular
farmworkers, who are landless, to own directly o collectively the lands
they till or, in the case of other farmworkers, to receive a just share of the
fruits thereof. To this end, the State shall encourage and undertake the just
distribution of all agricultural lands, subject to the priorities and retention
limits set forth in this Act, taking into account ecological, developmental,
and equity consideration, and subject to the payment of just compensation.
The State shall respect the rights of small landowners, and shall provide
incentive for voluntary land-sharing.

d. What are the principles that should guide the state in achieving this end?
- The State shall be guided by the principles that land has a social function
and land ownership has a social responsibility. Owners of agricultural
lands have the obligation to cultivate directly of through labor
administration the lands they own and thereby make the land productive.
C. The Issue of Constitutionality of the law (Re: Assoc. of Small Landowners in the
Philippines vs. The Secretary of Agrarian Reform)

e. Does the law violated the Equal Protection Clause?


- No. The Association had not shown any proof that they belong to a
different class exempt from the agrarian reform program. Under the law,
classification has been defined as the grouping of persons or things similar
to each other in certain particulars and different from each other in these
same particulars. To be valid, it must conform to the following
requirements:(1) it must be based on substantial distinctions;(2) it must be
germane to the purposes of the law;(3) it must not be limited to existing
conditions only; and(4) it must apply equally to all the members of the
class. Equal protection simply means that all persons or things similarly
situated must be treated alike both as to the rights conferred and the
liabilities imposed. The Association have not shown that they belong to a
different class and entitled to a different treatment. The argument that not
only landowners but also owners of other properties must be made to share
the burden of implementing land reform must be rejected. There is a
substantial distinction between these two classes of owners that is clearly
visible except to those who will not see. There is no need to elaborate on
this matter. In any event, the Congress is allowed a wide leeway in
providing for a valid classification. Its decision is accorded recognition
and respect by the courts of justice except only where its discretion is
abused to the detriment of the Bill of Rights. In the contrary, it appears
that Congress is right in classifying small landowners as part of the
agrarian reform program.

f. Does the law violated the right to Due Process?


- No. It is true that the determination of just compensation is a power lodged
in the courts. However, there is no law which prohibits administrative
bodies like the DAR from determining just compensation. In fact, just
compensation can be that amount agreed upon by the landowner and the
government even without judicial intervention so long as both parties
agree. The DAR can determine just compensation through appraisers and
if the landowner agrees, then judicial intervention is not needed. What is
contemplated by law however is that, the just compensation determined by
an administrative body is merely preliminary. If the landowner does not
agree with the finding of just compensation by an administrative body,
then it can go to court and the determination of the latter shall be the final
determination. As provided by RA 6557: Section 16 (f): Any party who
disagrees with the decision may bring the matter to the court of proper
jurisdiction for final determination of just compensation.
g. Does the Just Compensation, under the agrarian reform program, be in the form
of cash?
- No. Money as [sole] payment for just compensation is merely a concept
in traditional exercise of eminent domain. The agrarian reform program is
a revolutionary exercise of eminent domain. The program will require
billions of pesos in funds if all compensation have to be made in cash if
everything is in cash, then the government will not have sufficient money
hence, bonds, and other securities, i.e., shares of stocks, may be used for
just compensation.

Definitions
A. Agrarian Reform it is the redistribution of lands, regardless of crops or fruits produced
to farmers and regular farmworkers who are landless, irrespective of tenurial
arrangement, to include the totality of factors and support services designed to lift the
economic status of the beneficiaries and all other arrangements alternative to the physical
redistribution of lands, such as production or profit-sharing, labor administration, and the
distribution of shares of stocks, which will allow beneficiaries to receive a just share of
the fruits of the lands they work.

B. Agrarian Dispute it refers to any controversy relating to tenurial arrangements, whether


leasehold, tenancy, stewardship or otherwise, over lands devoted to agriculture, including
disputes concerning farmworkers' associations or representation of persons in
negotiating, fixing, maintaining, changing, or seeking to arrange terms or conditions of
such tenurial arrangements .

It includes any controversy relating to compensation of lands acquired under this


Act and other terms and conditions of transfer of ownership from landowners to
farmworkers, tenants and other agrarian reform beneficiaries, whether the disputants
stand in the proximate relation of farm operator and beneficiary, landowner and tenant, or
lessor and lessee.

C. Agricultural Land is a land devoted to agricultural activity as defined in this Act and
not classified as mineral, forest, residential, commercial or industrial land.

D. Landless Farmer it refers to a natural person whose primary livelihood is cultivation of


land or the production of agricultural crops, either by himself, or primarily with the
assistance of his immediate farm household, when the land is not owned by him, but by
another person under a leasehold or share tenancy agreement or arrangement with the
owner thereof.

E. Agricultural Tenant shall mean a person who, himself and with the aid available from
within his immediate farm household, cultivates the land belonging to, or possessed by,
another, with the latter's consent for purposes of production, sharing the produce with the
landholder under the share tenancy system, or paying to the landholder a price certain or
ascertainable in produce or in money or both, under the leasehold tenancy system.

F. Agricultural Tenancy Relationship a tenancy relationship is a juridical tie which arises


between a landholder and a tenant once they agree, expressly or impliedly, to undertake
jointly the cultivation of land belonging to the former, either under the share tenancy or
leasehold tenancy system, as a result of which relationship the tenant acquires the right to
continue working on and cultivating the land, until and unless he is dispossessed of his
holdings for any of the just causes enumerated in Section fifty or the relationship is
terminated in accordance with Section nine.

G. Stock Distribution Option a mode of complying with the land reform law that did not
require actual transfer of the land to the tiller; that instead of subdividing haciendas and
distributing small lots to tenants or small farmers, shares of stocks are issued to
beneficiaries through a stock distribution plan.

Rules of Coverage
Who are the beneficiaries of the Act?
- Landless farmers, including agricultural lessees, tenants, as well as
regular, seasonal and other farmworkers. The Department of Agrarian
Reform (DAR) identifies and screens potential beneficiaries and validates
their qualifications. For example, to qualify, you must be at least 15 years
old, be a resident of the barangay where the land holding is located, and
own no more than 3 hectares of agricultural land.

How much land is covered by the land reform?


- An estimated 7.8 million hectares of land is covered by CARP.

What are the lands covered by CARP?


a) All alienable and disposable lands of the public domain devoted to or
suitable for agriculture.
b) All lands of the public domain in excess of the specific limits as
determined by Congress
c) All other lands owned by the Government devoted to or suitable for
agriculture
d) All private lands devoted to or suitable for agriculture regardless of the
agricultural products raised or that can be raised thereon

What are the lands NOT covered by CARP?


a) Ancestral lands of each indigenous cultural community
b) Lands actually, directly and exclusively used for parks, wildlife, forest
reserves, reforestation, fish sanctuaries and breeding grounds, watersheds
and mangroves
c) Lands actually, directly and exclusively used for prawn farms and
fishponds
d) Lands with at least 18% slope
e) Lands actually, directly and exclusively used an found to be necessary
for national defense school sites and campuses experimental
farm stations operated for educational purposes seeds and seedling
research and pilot production center church sites and convents
mosque sites and Islamic centers communal burial grounds and
cemeteries penal colonies and penal farms govt and private
research and quarantine centers
f) landholdings of landowners with a total area of five (5) hectares and
below
g) lands devoted to the raising of livestock, poultry and swine [Luz Farms
v. Sec. of DAR]
h) lands obtained through homestead patent [Alita v. CA]
- EXCEPTION: lands obtained through homestead patent that are not being
personally cultivated by original homestead grantees or their direct
compulsory heirs [Paris v. Alfeche]
Rules of Acquisition
How will the government acquire landholdings?
- There are different modes of acquiring and distributing public and private
agricultural lands. For private lands under compulsory acquisition, the
DAR will issue Notices of Coverage to the original owners of the
landholdings. Notices of Coverage will be issued to most of the
landholdings by June 30, 2014. A Notice of Coverage (NOC) is a letter
informing a landowner that his/her land is covered by CARP, and is
subject to acquisition and distribution to beneficiaries. It likewise informs
the landowner of his/her rights under the law, including the right to retain
5 hectares.

What are the procedures in the compulsory land acquisition?


- 1) Identification by the DAR of the land, landowner & beneficiary
- 2) Notice by the DAR to the landowner about the compulsory acquisition
and the price offer thru:
a) By personal notice or registered mail
b) Posting of notice in a conspicuous place in the brgy hall &
municipal hall where the land is located
- 3) Reply by the landowner about his acceptance or rejection of the offered
price:
a) Landowner accepts Landbank will pay the landowner within
30 days from execution & delivery of Deed of Transfer
b) Landowner rejects DAR will determine the just compensation
thru the summary administrative proceedings
c) Landowner disagrees with the DAR decision landowner may
bring the matter to the regular courts of justice for final determination of
just compensation
- 4) Taking of immediate possession of the land by the DAR:
a) If the landowner receives the corresponding payment; or
b) if the landowner does not respond to the Notice of Acquisition
- 5) Request by the DAR to Register of Deeds to issue a Transfer Certificate
of Title to the Republic of the Phil.
- 6) Distribution of lands to then qualified beneficiaries.

What are the modes of land acquisition?


- a) Voluntary offer to sell
- b) Compulsory acquisition
- c) Voluntary land transfer
Rules of Distribution
How are lands distributed?
1. Land Transfer (Voluntarily Offer to Sell or Compulsory Acquisition)
a. General rule: Lands shall be distributed directly to the individual farmworker-
beneficiaries.

b. Exception: However, if it is not economically feasible and sound to divide the


land, then it shall be owned collectively by the farmworker-beneficiaries through
a workers' cooperative or association. [Section 29]

c. In case the land is transferred to a cooperative or association, the individual


members of the cooperatives shall be provided with homelots and small farmlots
for their family use, to be taken from the land owned by the cooperative. [Section
30]
2. Capital Stock Transfer [Section 31]
a. This is a non-land transfer. Corporations or associations which voluntarily
divest a proportion of their capital stock, equity or participation in favor of their
workers or other qualified beneficiaries shall be deemed to have complied with
CARL.

b. Amount to be divested: Corporations owning agricultural lands may give their


qualified beneficiaries the right to repurchase such proportion of the capital stock
of the corporation that the agricultural land, actually devoted to agricultural
activities, bears in relation to the company's total assets. * Agricultural activity
means the cultivation of the soil, planting of crops, growing of fruit trees, raising
of fish, including the harvesting of such farm products, and other farm activities
and practices performed by a farmer in conjunction with such farming operations
done by persons whether natural or juridical [Section 3(b)].

c. Conditions of the Capital Stock Transfer.


i. The books of the corporation shall be subject to periodic audit by
certified public accountants chosen by the beneficiaries;
ii. The beneficiaries shall be assured of at least one (1) representative in
the board of directors, or in a management or executive committee, if one exists;
iii. Any share acquired by the beneficiaries shall have the same rights and
features as all other shares; and
iv. Any transfer of shares of stock by the original beneficiaries shall be
void ab initio unless said transaction is in favor of a qualified and registered
beneficiary within the same corporation.

d. Period for Compliance: If within TWO (2) YEARS from the approval of
CARL or from the approval of the PARC of the plan for stock distribution, the
stock transfer is not made or realized, the agricultural land shall be subject to
compulsory coverage of the CARL.

Primer on R.A. 9700 or the Comprehensive Agrarian Reform Program Extension with
Reforms:

What was extended?


- CARPER, or the Comprehensive Agrarian Reform Program Extension
with Reforms, is the amendatory law that extends yet again the deadline of
distributing agricultural lands to farmers for five years. It also amends
other provisions stated in CARP. CARPER was signed into law on August
7, 2009.

What are the reforms introduced?


Gender-Sensitive Agrarian Reform Section 1 of the CARPER law
states that "The State shall recognize and enforce, consistent with existing
laws, the rights of rural women to own and control land, taking into
consideration the substantive equality between men and women as
qualified beneficiaries, to receive a just share of the fruits thereof, and to
be represented in advisory or appropriate decision-making bodies. These
rights shall be independent of their male relatives and of their civil status."
Rural women will have a representative in the highest policy making body
of DAR the Presidential Agrarian Reform Council (PARC).
Budget Section 21 amending Section 63 for CARL state that the budget
allocated for the 5-year extension is 150 Billion pesos which will be
sourced from three funds: Agrarian Reform Fund, General Appropriations
Acts (GAA) and other sources of funding like privatization of government
asset, foreign donors, etc. This budget is the largest per year in the history
of CARP.
Creation of a Congressional Oversight Committee Section 26 of the
CARPER law created a joint Congressional Oversight Committee to
oversee and monitor the implementation of the act, which will be
composed of the Chairpersons of the Committee on Agrarian Reform of
both Houses of Congress, three Members of the House of Representatives,
and three Members of the Senate of the Philippines, to be designated
respectively by the Speaker of the House of Representatives and the
President of the Senate of the Philippines. The chairpersons of the
COCAR are the Chairpersons of the Committees on Agrarian Reform of
the House of Representatives and of the Senate of the Philippines. The
term of the COCAR will end six months after the expiration of the
extended period of five years. The COCAR is provided with twenty-five
million pesos (P25,000,000.00) every year.
CARPER as a Continuing Program Section 30 of the CARPER law
mandates that any case and/or proceeding involving the implementation
of the provisions of Republic Act No. 6657, as amended, which may
remain pending on June 30, 2014 shall be allowed to proceed to its finality
and be executed even beyond such date". Section 30 of CARPER law
provides a way to legally continue the implementation of pending CARP
cases after the 5-year extension by filling the initiatory process of CARP.
Policies in Converting Agricultural Lands Section 73 of the CARPER
law: "Any conversion by any landowner of his/her agricultural land into
any non-agricultural use with intent to avoid the application of this Act to
his/her landholdings and to dispossess his/her bonafide tenant farmers."
Failure to comply will result in an imprisonment of 6 to 12 years and/or a
penalty of 200,000 pesos to 1 million pesos. The CARPER law prohibits
any conversion of irrigated and irrigable lands and mandates the National
Irrigation Administration to identify these. CARPER law also states that
non-implementation of the conversion plan will result to automatic
coverage of the subject by CARP.
Hacienda Luisita Inc. (HLI) v. Presidential Agrarian Reform Council (PARC), et al.,
G.R. No. 171101, November 22, 2011

FACTS:
On July 5, 2011, the Supreme Court en banc voted unanimously (11-0) to
DISMISS/DENY the petition filed by HLI and AFFIRM with MODIFICATIONS the resolutions
of the PARC revoking HLIs Stock Distribution Plan (SDP) and placing the subject lands in
Hacienda Luisita under compulsory coverage of the Comprehensive Agrarian Reform Program
(CARP) of the government.
The Court however did not order outright land distribution. Voting 6-5, the Court noted
that there are operative facts that occurred in the interim and which the Court cannot validly
ignore. Thus, the Court declared that the revocation of the SDP must, by application of the
operative fact principle, give way to the right of the original 6,296 qualified farmworkers-
beneficiaries (FWBs) to choose whether they want to remain as HLI stockholders or [choose
actual land distribution]. It thus ordered the Department of Agrarian Reform (DAR)
to immediately schedule meetings with the said 6,296 FWBs and explain to them the effects,
consequences and legal or practical implications of their choice, after which the FWBs will be
asked to manifest, in secret voting, their choices in the ballot, signing their signatures or placing
their thumbmarks, as the case may be, over their printed names.
The parties thereafter filed their respective motions for reconsideration of the Court decision.
ISSUE/s:
(1) Is the operative fact doctrine available in this case?
(2) Is Sec. 31 of RA 6657 unconstitutional?
(3) Cant the Court order that DARs compulsory acquisition of Hacienda Lusita cover the full 6,443
hectares allegedly covered by RA 6657 and previously held by Tarlac Development Corporation
(Tadeco), and not just the 4,915.75 hectares covered by HLIs SDP?
(4) Is the date of the taking (for purposes of determining the just compensation payable to HLI)
November 21, 1989, when PARC approved HLIs SDP?
(5) Has the 10-year period prohibition on the transfer of awarded lands under RA 6657 lapsed on
May 10, 1999 (since Hacienda Luisita were placed under CARP coverage through the SDOA
scheme on May 11, 1989), and thus the qualified FWBs should now be allowed to sell their land
interests in Hacienda Luisita to third parties, whether they have fully paid for the lands or not?
(6) THE CRUCIAL ISSUE: Should the ruling in the July 5, 2011 Decision that the qualified FWBs
be given an option to remain as stockholders of HLI be reconsidered?

HELD:
[The Court PARTIALLY GRANTED the motions for reconsideration of respondents PARC,
et al. with respect to the option granted to the original farmworkers-beneficiaries (FWBs) of
Hacienda Luisita to remain with petitioner HLI, which option the Court
thereby RECALLED and SET ASIDE. It reconsidered its earlier decision that the qualified
FWBs should be given an option to remain as stockholders of HLI, and UNANIMOUSLY
directed immediate land distribution to the qualified FWBs.
1. YES, the operative fact doctrine is applicable in this case.
[The Court maintained its stance that the operative fact doctrine is applicable in this
case since, contrary to the suggestion of the minority, the doctrine is not limited only to invalid or
unconstitutional laws but also applies to decisions made by the President or the administrative
agencies that have the force and effect of laws. Prior to the nullification or recall of said
decisions, they may have produced acts and consequences that must be respected. It is on this
score that the operative fact doctrine should be applied to acts and consequences that resulted
from the implementation of the PARC Resolution approving the SDP of HLI. The majority
stressed that the application of the operative fact doctrine by the Court in its July 5, 2011
decision was in fact favorable to the FWBs because not only were they allowed to retain the
benefits and homelots they received under the stock distribution scheme, they were also given
the option to choose for themselves whether they want to remain as stockholders of HLI or not.]
2. NO, Sec. 31 of RA 6657 NOT unconstitutional.
[The Court maintained that the Court is NOT compelled to rule on the constitutionality of
Sec. 31 of RA 6657, reiterating that it was not raised at the earliest opportunity and that the
resolution thereof is not the lis mota of the case. Moreover, the issue has been rendered moot
and academic since SDO is no longer one of the modes of acquisition under RA 9700. The
majority clarified that in its July 5, 2011 decision, it made no ruling in favor of the
constitutionality of Sec. 31 of RA 6657, but found nonetheless that there was no apparent grave
violation of the Constitution that may justify the resolution of the issue of constitutionality.]
3. NO, the Court CANNOT order that DARs compulsory acquisition of Hacienda Lusita
cover the full 6,443 hectares and not just the 4,915.75 hectares covered by HLIs SDP.
[Since what is put in issue before the Court is the propriety of the revocation of the SDP,
which only involves 4,915.75 has. of agricultural land and not 6,443 has., then the Court is
constrained to rule only as regards the 4,915.75 has. of agricultural land. Nonetheless, this
should not prevent the DAR, under its mandate under the agrarian reform law, from
subsequently subjecting to agrarian reform other agricultural lands originally held by Tadeco
that were allegedly not transferred to HLI but were supposedly covered by RA 6657.
However since the area to be awarded to each FWB in the July 5, 2011 Decision
appears too restrictive considering that there are roads, irrigation canals, and other portions of
the land that are considered commonly-owned by farmworkers, and these may necessarily
result in the decrease of the area size that may be awarded per FWB the Court reconsiders
its Decision and resolves to give the DAR leeway in adjusting the area that may be awarded per
FWB in case the number of actual qualified FWBs decreases. In order to ensure the proper
distribution of the agricultural lands of Hacienda Luisita per qualified FWB, and considering that
matters involving strictly the administrative implementation and enforcement of agrarian reform
laws are within the jurisdiction of the DAR, it is the latter which shall determine the area with
which each qualified FWB will be awarded.
On the other hand, the majority likewise reiterated its holding that the 500-hectare
portion of Hacienda Luisita that have been validly converted to industrial use and have been
acquired by intervenors Rizal Commercial Banking Corporation (RCBC) and Luisita Industrial
Park Corporation (LIPCO), as well as the separate 80.51-hectare SCTEX lot acquired by the
government, should be excluded from the coverage of the assailed PARC resolution. The Court
however ordered that the unused balance of the proceeds of the sale of the 500-hectare
converted land and of the 80.51-hectare land used for the SCTEX be distributed to the FWBs.]
4. YES, the date of taking is November 21, 1989, when PARC approved HLIs SDP.
[For the purpose of determining just compensation, the date of taking is November 21,
1989 (the date when PARC approved HLIs SDP) since this is the time that the FWBs were
considered to own and possess the agricultural lands in Hacienda Luisita. To be precise, these
lands became subject of the agrarian reform coverage through the stock distribution scheme
only upon the approval of the SDP, that is, on November 21, 1989. Such approval is akin to a
notice of coverage ordinarily issued under compulsory acquisition. On the contention of the
minority (Justice Sereno) that the date of the notice of coverage [after PARCs revocation of the
SDP], that is, January 2, 2006, is determinative of the just compensation that HLI is entitled to
receive, the Court majority noted that none of the cases cited to justify this position involved the
stock distribution scheme. Thus, said cases do not squarely apply to the instant case. The
foregoing notwithstanding, it bears stressing that the DAR's land valuation is only preliminary
and is not, by any means, final and conclusive upon the landowner. The landowner can file an
original action with the RTC acting as a special agrarian court to determine just compensation.
The court has the right to review with finality the determination in the exercise of what is
admittedly a judicial function.]
5. NO, the 10-year period prohibition on the transfer of awarded lands under RA 6657 has
NOT lapsed on May 10, 1999; thus, the qualified FWBs should NOT yet be allowed to sell
their land interests in Hacienda Luisita to third parties.
[Under RA 6657 and DAO 1, the awarded lands may only be transferred or conveyed
after 10 years from the issuance and registration of the emancipation patent (EP) or certificate
of land ownership award (CLOA). Considering that the EPs or CLOAs have not yet been issued
to the qualified FWBs in the instant case, the 10-year prohibitive period has not even started.
Significantly, the reckoning point is the issuance of the EP or CLOA, and not the placing of the
agricultural lands under CARP coverage. Moreover, should the FWBs be immediately allowed
the option to sell or convey their interest in the subject lands, then all efforts at agrarian reform
would be rendered nugatory, since, at the end of the day, these lands will just be transferred to
persons not entitled to land distribution under CARP.]

6. YES, the ruling in the July 5, 2011 Decision that the qualified FWBs be given an option to
remain as stockholders of HLI should be reconsidered.
[The Court reconsidered its earlier decision that the qualified FWBs should be given an
option to remain as stockholders of HLI, inasmuch as these qualified FWBs will never gain
control [over the subject lands] given the present proportion of shareholdings in HLI. The Court
noted that the share of the FWBs in the HLI capital stock is [just] 33.296%. Thus, even if all the
holders of this 33.296% unanimously vote to remain as HLI stockholders, which is unlikely,
control will never be in the hands of the FWBs. Control means the majority of [sic] 50% plus at
least one share of the common shares and other voting shares. Applying the formula to the HLI
stockholdings, the number of shares that will constitute the majority is 295,112,101 shares
(590,554,220 total HLI capital shares divided by 2 plus one [1] HLI share). The 118,391,976.85
shares subject to the SDP approved by PARC substantially fall short of the 295,112,101 shares
needed by the FWBs to acquire control over HLI.]
Rosalinda Bonifacio et. al., v. Judge Dizon
G.R. No, 79416

FACTS:
Olimpio Bonifacio as the owner of a land which the private respondent, Pastora San
Miguel, was an agricultural lessee. On July 1, 1968, Olimpio filed a complaint seeking the
ejectment of private respondent from Bonifacios 2-hectare agricultural land. The CAR granted
the ejectment of Pastora San Miguel. On appeal by the private respondent, the CA modified the
judgement with respect to her counterclaim by ordering Olimpio to pay her in P1,376.00. Still
dissatisfied, private respondent sought relief to SC. During the pendency of the case, Olimpio
died andwas succeeded by his heirs. However, no notice of such death was given to the Court,
hence no order of substitution of his heirs was made. SC resolved to deny the petition of the
private respondent for lack of merit, SC affirmed the decision of CA. Subsequently, petitioners
(heirs of Olimpio) moved for the execution of the decision by RTC of Bulacan. The Deputy
Sheriff submitted his report stating in part that except for a portion thereof occupied by the
private respondent which the latter refused the vacate. Private respondent moved to quash the
execution. RTC held the decision of the sheriff to be null and void, and that the motion for
demolition was denied. Petitioners conteded that the judge committed grave abuse of discretion.
They assert that the CAR case, being an ejectment case survives the death of a party. Private
respondent, on the other hand, stress on the fact that the action is not an ordiary ejectment but an
agrarian case for the ejectment of the agricultural lessee.
ISSUE:
Won, the compulsory heirs inherit the favorable judgment obtained by the decedent,
thereby vesting to the former, all rights conferred by the judgment to the decedent.
RULING:
Petition is granted. SC reads Sec. 36 (1), R.A. 3844, which provides, for the continuation
in the enjoyment and possession of an agricultural lessee of his landholding except when his
dispossession has been authorized by the Court in a judgment that is final and executory. Under
such provision, the ejectment of an agricultural lessee was authorized not only when the
landowner-lessor desired to cultivate the landholding, but also when a member of his immediate
family so desired. The right of cultivation was extended to the landowners immediate family
members evidently to place the landowner-lessor in parity with the agricultural lessee who was
(and still) allowed to cultivate the land with the aid of his farm household. Whether used in
reference to the agricultural lessor or lessee, the term personal cultivation cannot b given
restricted connotation to mean a right personal and exclusive to either the lessor or lessee. In
either case, the right extends to the members of the lessors or lessees immediate family. The
CAR case not being a purely personal right, the same was transmitted to petitioners as heirs and
successors-in-interest.

Spouses Pagtalunan vs. Honorable Dizon G.R. No. L-54281 March 19, 1990
FACTS:
Respondent Republic of the Philippines filed a complaint for expropriation of a parcel of
land located in Bo. Tikay, Malolos, Bulacan, and owned by the Aldabas (as evidenced by a TCT
issued by the Register of Deeds of the province of Bulacan). The CFI issued a writ of possession
placing the Republic in possession of the land, upon its deposit of P7,200.00 as provisional value
of the land.Petitioners (sp. Pagtalunans) filed a supplemental motion for leave to intervene, with
complaint in intervention attached thereto, alleging that petitioner Celso Pagtalunan has been the
bona fide agricultural tenant of a portion of the land. Petitioners asked the trial court to order
payment to Celso Pagtalunan of just compensation for his landholding or, in the alternative, to
order payment of his disturbance compensation as bona fide tenant in an amount not less than
P15,000.00 per hectare. December 8, 1978 Order: respondent Judge Roque A. Tamayo denied
the petitioners' supplemental motion, holding that to admit petitioners' complaint in intervention
would be tantamount to allowing a person to sue the State without its consent since the claim for
disturbance compensation is a claim against the State. Petitioners filed a motion for
reconsideration but this was denied by respondent judge. Thus, the petitioners filed an instant
petition, which was denied for lack of merit. Petitioners filed a motion for reconsideration,
limiting the discussion on the issue of lack of jurisdiction of the trial court over the expropriation
case. The Court granted the motion for reconsideration and gave due course to the petition.
December 22, 1978: The OSG (appealing from the portion of the December 8, 1978 decision of
the CFI which fixed the compensation for the land expropriated at P30.00 per square meter) filed
in behalf of the Republic of the Philippines a notice of appeal and a first motion for extension of
30 days from January 12, 1979 within which to file record on appeal which was granted by
respondent court. Counsel for private respondents filed an objection to the public respondent's
record on appeal claiming that the same was filed beyond the reglementary period. The CFI
dismissed the appeal interposed by the Republic. The OSG moved for reconsideration but this
was denied for lack of merit. The public respondent filed a petition for certiorari , prohibition
and mandamus with preliminary injunction seeking the annulment of the CFI orders. The CA
dismissed public respondent's petition. The public respondent filed a petition asking this Court to
annul the CA decision and to direct and compel the lower court to approve the Government's
record on appeal and to elevate the same to the CA. In a decision dated August 10, 1981, the
Court granted the petition and directed the trial court to approve the Government's record on
appeal and to elevate the same to the CA.
ISSUE:
Whether or not the petitioners had the right to intervene in the expropriation proceedings
instituted by the State against the Aldabas (private respondents) as registered owners of the
subject property.
HELD:
Petition is denied for lack of merit. - Intervention is not a matter of right but may be
permitted by the courts when the applicant shows facts which satisfy the requirements of the law
authorizing intervention. Under Section 2, Rule 12 of the Revised Rules of Court, what qualifies
a person to intervene is his possession of a legal interest in the matter in litigation, or in the
success of either of the parties, or an interest against both, or when he is so situated as to be
adversely affected by a distribution or other disposition of property in the custody of the court or
an officer thereof. Such interest must be actual, direct and material, and not simply contingent
and expectant.
The Court is fully aware that the phrase "deemed to be the owner" is used to describe
the grantee of a certificate of land transfer. But the import of such phrase must be construed
within the policy framework of Pres. Decree No. 27, and interpreted with the other stipulations
of the certificate issued pursuant to this decree. Pres. Decree No. 27 (Tenant Emancipation
Decree) recognized the necessity to encourage a more productive agricultural base of the
country's economy. To achieve this end, the decree laid down a system for the purchase by small
farmers, long recognized as the backbone of the economy, of the lands they were tilling. A
careful study of the provisions of Pres. Decree No. 27, and the certificate of land transfer issued
to qualified farmers, will reveal that the transfer of ownership over these lands is subject to
particular terms and conditions the compliance with which is necessary in order that the grantees
can claim the right of absolute ownership over them.
Ramon A. Gonzales vs Land Bank of the Philippines and Court of Appeals
G.R. No. 76759 March 22, 1990
FACTS:
On the strength of a Deed of Assignment executed on August 8, 1981 by Ramos Plantation
Company, Inc. (hereafter referred to as the corporation) through its president, Antonio Vic
Zulueta, assigning its rights under Land Transfer Claim No. 82-757 unto petitioner Ramon A.
Gonzales, the latter filed an action before the Regional Trial Court of Manila, to compel public
respondent Land Bank of the Philippines to issue Land Bank Bonds for the amount of
P400,000.00 in the name of petitioner instead of in the name of the aforesaid corporation as the
original and registered owner of the property which had been brought under the land transfer
program of the government.
Defendant corporation was declared in default for failure to file its answer within the
reglementary period while defendant Land Bank filed an answer alleging that the complaint
states no cause of action since there is no privity of contract between plaintiff and itself and that
it deals only with the landowner whose land was subjected to operation land transfer of the
government under Presidential Decree No. 27 in order to save time and effort in ascertaining the
identities of additional claimants.
ISSUE:
Whether respondent Land Bank can be compelled to issue Land Bank bonds in the name
of petitioner by virtue of the Deed of Assignment executed by the landowner-assignor Ramos
Plantation Company, Inc. in favor of petitioner.
HELD:
However, petitioner relying on the provisions of Article 1311 of the Civil Code, 8
maintains that by virtue of said deed, he stepped into the shoes of his assignor and acquired all
the rights of the latter and it was error on the part of the appellate court to find that the aforesaid
Deed of Assignment is not effective to authorize the Land Bank of the Philippines to issue the
Land Bank Bonds in the name of petitioner upon compliance with the remaining six (6)
requirements for the first release thereof. The act of assignment could not operate to erase liens
or restrictions burdening the right assigned. The assignee cannot, after all, acquire a greater right
than that pertaining to the assignor.
This Court is in total agreement with respondent appellate court's finding that it must be
the Ramos Plantation Company, Inc. which should comply with all the requirements imposed by
respondent bank to effect the release of payments under land transfer claims because of the
restriction that the bonds will only be released in the name of the landowner-assignor corporation
which may thereafter indorse the same to petitioner. In fact, in the decision of the trial court,
Ramos Plantation Company, Inc. was directed to comply with the six (6) requirements 12 listed in
paragraph 1 of the Supplemental Stipulation of Facts dated September 10, 1985. Since no appeal
was taken by Ramos Plantation Company, Inc. from said decision, said directive has become
final and executory.
Talavera vs. Laxamana
GR. 77830
Facts:
Jose Laxamana instituted an action for recovery of possession on July 10, 1984 against the
petitioners over a parcel of land located in Brgy. Sto. Domingo 11, Sition Tambo, Capas Tarlac.
Private respondent alleged that he had been a bonafide tenant of the said land since 1958. He had
been in continuous possession of the said land until the petitioners took possession of it and
planted palay without private respondents knowledge and through force and intimidation. The
private respondent suffered damages amounting to P500.00 and the price equivalent to sixty-five
cavans of palay per agricultural year. In the petitioners defence, they stated that the taking of the
private respondents possession was in accordance with their Casunduan executed on March
30, 1973 and that he was not actually a tenant of the petitioners. The document states that private
respondent sold his rights and interests over the property for a consideration of P1, 000.00. The
Regional Trial Court ruled in favour of the private respondent to which the petitioners appealed
in the Court of Appeals. The Court of Appeals affirmed the lower courts decision that the
Casunduan did not constitute valid surrender of the land contemplated under the law.
Issue: Whether or not the surrender of the land by the private respondent constitutes valid
surrender contemplated by the law
Held:
No, the surrender did not constitute a valid surrender as contemplated by the law. The
Decision of the RTC and the CA is affirmed. Under the Code of Agrarian Reforms of the
Philippines (R.A. No. 3844) Section 8, agricultural leasehold shall only be extinguished based
on the following grounds: 1. Abandonment of the landholding without the knowledge of the
agricultural lessor; 2. Voluntary surrender of the landholding by the agricultural lessee, written
notice of which shall be served three months in advance; or 3. Absence of the person under
Section rune to succeed to the lessee, in the event of death or permanent incapacity of the lessee.
Voluntary surrender does not require any court authorization since it involves the tenants own
volition however, it must be shown that the surrender was voluntary through convincing and
sufficiently proved evidence. It cannot be presumed nor implied otherwise, the right of the tenant
to security of tenure becomes illusory one. It was shown that the Casunduan was prepared by
petitioner Visitacion Talavera and that Jose Laxamana, at the time the Casunduan was made,
needed money for his wifes illness which later caused her death. Laxamana could also hardly
sign his own name. Laxamana also continued working on the land until 1984 even after the
Casunduan was made while the Talaveras claimed that they cultivated the land themselves.
Exhibits presented as evidence showed that Talaveras did not cultivate the land and actually
resides in another barangay. The circumstances showed that Laxamana was forced to sign the
Casunduan without fully understanding it and continued cultivating the land after.

Bernas vs. Court of Appeals 225 SCRA 119 (1993)


Facts:
Natividad Deita is the owner of a 5,831-sq m property which she entrusted to her brother,
Benigno, so that he could use the fruits thereof to defray the cost of his children's education in
Manila. The property was leased by Bernas pursuant to a production sharing arrangement
executed between Bernas and Benigno. Natividad played no part in this arrangement. In 1985,
the lots were returned by Benigno to his sister but when the owners sought to take possession,
Bernas refused to relinquish the property. Bernas was claiming that he was an agricultural lessee
entitled to security of tenure. Natividad filed an action for recovery of possession. The trial court
ruled in favor of Bernas but this was subsequently reversed by the CA.
Issue:
Is consent by a legal possessor, even if without the consent of landowner, sufficient to
create tenancy relationship?
Held:
Yes. As legal possessor of the property, Benigno had the authority and capacity to enter
into an agricultural leasehold relation with Bernas. "The law expressly grants him, as legal
possessor, authority and capacity to institute an agricultural leasehold lessee on the property he
legally possessed." (at 125-126) Subject is agricultural land For agricultural tenancy to
exist, the subject of the agreement must be an agricultural land. RA 6657 defines the term
"agricultural land" as "land devoted to agricultural activity as defined in this Act and not
classified as mineral, forest, residential, commercial or industrial land." (see discussion on scope
of CARP, Chapter I). Under RA 3844, "agricultural land" refers to land devoted to any growth,
including but not limited to crop lands, salt beds, fish ponds, idle land and abandoned land.
The area of agricultural land that a lessee may cultivate has no limit, but he should cultivate the
entire area leased. The three (3) hectare limit under RA 6657 applies only to the award that may
be given to the agrarian reform beneficiary. Consent by landholder As discussed earlier,
consent must be given by the true and lawful landholder of the property. In Hilario vs. IAC, 148
SCRA 573 (1987), the Supreme Court held that tenancy relation does not exist where a usurper
cultivates the land.

Nisnisan, et al vs. Court of Appeals


294 SCRA 173 (1998)
Facts:
Spouses Gavino and Florencia Nisnisan are the owners of a 4.9774 hectare land in Davao
del Sur. Policarpio, the son of Gavino, has been cultivating one (1) ha of said land since 1961. In
1976, Gavino and Policarpio executed a leasehold contract which stipulates a sharing
arrangement of 1/3:2/3 of the harvest. In 1978, Gavino sold two (2) ha of the land, including the
land tenanted by Policarpio, to spouses Mancera. As a result of the sale, Policarpio and family
were ousted. They then filed an action for reinstatement of tenancy against the Manceras. The
Manceras, on the other hand, countered that spouses Nisnisan have no cause of action because
they voluntarily surrendered their landholding.
Issue:
Is the tenant deemed to have voluntarily surrendered subject landholding?
Held:
Other than their bare allegations, private respondents failed to present any evidence to show
that petitioners-spouses surrendered their landholding voluntarily after the private respondents
purchased the subject property. Moreover, the filing of the complaint for reinstatement of
leasehold tenancy by petitioners-spouses against private respondents before the CAR militates
against the private respondents' claim that petitioners-spouses voluntarily surrendered their
landholding to them. Under Sec. 8 of RA 3844, voluntary surrender, as a mode of extinguishing
agricultural leasehold tenancy relations, must be convincingly and sufficiently proved by
competent evidence. The tenant's intention to surrender the landholding cannot be presumed,
much less determined by mere implication.
Cecilleville Realty and Services Corporation vs. Court of Appeals, et al.
G.R. No. 120363 September 5 1997
FACTS:
Cecilleville Realty and Services Corporation (Petitioner) is an owner of a parcel of land in
Catmon, Sta. Maria, Bulacan. Ana Pascual (Pascual) is a tenent of the said land and thus lives
within a parcel of land therein. Her son, Herminigildo Pascual ( Private Respondent), assists her
in her duties as a tenant since she is already of old age and infirm. The respondent does not live
in the home of Pascual, but instead has his own home in the same portion of land. Despite the
repeated demands of the petitioner for the private respondent to vacate the land, the respondent
refuses to do so since he helps his mother to tend the land which she is entitled to. STATEMENT
OF THE CASE: Petitioner instituted an ejectment suit against the private respondent before the
Municipal Trial Court (MTC) of Sta. Maria, Bulacan. The MTC ordered private respondent to
vacate the land and pay the some of P500 monthly from the filing of the complaint. Private
Respondent appealed to the Regional Trial Court (RTC) which set aside the decision of the MTC
and remanded the case to the Department of Agrarian Reform Adjudication Board (DARAB).
Petitioner moved for reconsideration, but to no avail, hence petitioner appealed to the Court of
Appeals (CA). The CA dismissed the petition since it was devoid of merit. Dissatisfied petitioner
filed the instant petition for review on certiorari to this court.
ISSUE:
Whether or not private respondent is a tenant of the said land which entitles him to create
an abode of his own.
RULING:
Petition is GRANTED According to Republic Act no. 1199, as amended by RA 2263,:
Sec. 5. (a) A tenant shall mean a person who, himself and with the aid available from within
his immediate farm household, cultivates the land belonging to, or possessed by, another, with
the latters consent for purposes of production, sharing the produce with the landholder under the
share tenancy system, or paying to the landholder a price certain or ascertainable in produce or in
money or both, under the leasehold tenancy system. (o) Immediate farm household includes the
members of the family of the tenant, and such other persons, whether related to the tenant or not,
who are dependent upon him for support and who usually help him operate the farm enterprise.
It cannot be argued that the private respondent is entitled to help his mother in cultivating his
land since he is an immediate member of of Ana Pascual's family. What is of concern is that only
a tenant may construct and maintain his/her house in the said portion of land. Said home must be
no more than 3% of the total land area of his land holding and provided that it does not exceed
1000 sqm. The purpose of the act is to "afford adequate protection to the rights of BOTH tenants
and landholders". It would be unfair to the land owners if the courts would sustain the arguments
of the private respondent. The land would no longer be for efficient agricultural production but
instead will become a residential area filled with colonies of houses.
Aniceto M. Quino vs. Court of Appeals G.R. No. 118599 June 26, 1998
FACTS:
On 29 October 1974 Bernarda and Rosario Galan sold their agricultural land with an area
of 2.3926 hectares situated in Basak, Compostela, Cebu, to spouses Antonio Leonardo Sr. and
Josefa Galan for P2,000.00. More than a decade later, or on 30 October 1986, petitioner Aniceto
Quio filed a complaint for redemption of the property against the vendees claiming that he had
been instituted as tenant thereon by the Galans since 1951; consequently, he had the right to be
notified in writing of the owners' intention to sell the property to enable him to exercise his right
of preemption under Sec. 11 of RA No. 3844 2 but that notwithstanding the Galans had not
informed him of the sale. He claimed that he learned of the transaction only on 1 September
1986 when he found out that the Leornardos were already the new owners. He therefore prayed
that he be allowed to redeem the property and consigned the purchase price with the trial court
on the same day he filed his complaint.
ISSUE:
Whether or not the petitioner could redeem the property from respondent Bitoon unless the
latter decided to sell it on the strength of the ruling in Velasquez v. Nery.
HELD:
Simply stated, in the event that the landholding is sold to a third person without the
knowledge of the agricultural lessee, the latter is granted by law the right to redeem it within one
hundred eighty (180) days from notice in writing and at a reasonable price and consideration.
Petitioner was not notified of the first and second instances of sale of the property apparently
because all the respondents disputed petitioner's assertion that he has been a tenant thereon since
1951. These instances of sale without notification gave rise to his right to redeem the property as
lessee although no longer from the Leonardos but from its present owner, respondent Bitoon.
The purpose of the written notice required by law its to remove all uncertainties as to the
sale, its terms and its validity, and to quiet any doubts that the alienation is not definitive. The
law does not prescribe any particular form of notice, nor any distinctive method for notifying the
redemptioner. So long as the redemptioner is informed in writing of the sale and the particulars
thereof, the period for redemption will start running.
The preceding discussion leads us to the requirement concerning reasonable price and
consideration. An offer to redeem to be properly effected can either be through a formal tender
with consignation or by filing a complaint in court coupled with consignation of the redemption
price within the prescribed period. 10 It must be stressed however that in making a repurchase it is
not sufficient that a person offering to redeem merely manifest his desire to purchase; this
statement of intention must be accompanied by an actual and simultaneous tender of payment
which constitutes the legal use or exercise of the right to repurchase. And the tender of payment
must be for the full amount of the repurchase price, otherwise the offer to redeem will be held
ineffectual. As to what constitutes reasonable price and consideration, the valuation placed by the
Leonardo spouses and respondent Bitoon themselves as price of the land must be taken to be
such reasonable price and consideration.
Hence we reiterate that, for of petitioner to consign the entire redemption price, there was
no valid exercise by him of his legal right to redeem.
CENTRAL MINDANAO UNIVERSITY, petitioner, vs. DARAB, et.al., respondents
G.R. No. 100091, October 22, 1992
FACTS:
The petitioner, the CMU, is an agricultural education institution owned and run by the
estate located in the town of Musuan, Bukidnon province. It started as a farm school at Marilag,
Bukidnon, in early 1910, in response to the public demand for an agricultural school in
Mindanao. In the early 1960's, it was converted into a college until it became what is now
known as the CMU, but still primarily an agricultural university. On January 16, 1958 the late
Carlos P. Garcia, issued Proclamation No. 467, withdrawing from sale or settlement and
reserving for the Mindanao Agricultural College, a site which would be the future campus of
what is now the CMU. A total land area comprising 3,080 hectares was surveyed and registered
and titled in the name of the petitioner.Several tribes belonging to cultural communities, opposed
the petition claiming ownership of certain ancestral lands forming part of the tribal reservations.
Some of the claims were granted so that what was titled to the present petitioner school was
reduced from 3,401 hectares to 3,080 hectares. In 1984, the CMU approved Resolution No. 160,
adopting a livelihood program called "Kilusang Sariling Sikap Program" under which the land
resources of the University were leased to its faculty and employees. This arrangement was
covered by a written contract. The faculty and staff combine themselves to groups of five
members each, and the CMU provided technical know-how, practical training and all kinds of
assistance, to enable each group to cultivate 4 to 5 hectares of land for the lowland rice projects.
Each group pays the CMU a service fee and also a land use participant's fee. It was expressly
stipulated that no landlord-tenant relationship existed between the CMU and the faculty and/or
employees. This particular program was conceived as a multi-disciplinary applied research
extension and productivity program to utilize available land, train people in modern agricultural
technology and at the same time give the faculty and staff opportunity within the confines of the
CMU reservation to earn additional income to augment their salaries. Among the participants in
this program were Alvin Obrique, Felix Guinanao, Joven Caballero, Nestor Pulao, Danilo
Vasquez, Aronio Pelayo and other complainants (respondents). Obrique was a Physics Instructor
at the CMU while the others were employees in the lowland rice project. In 1986, the agri-
business project for the production of rice, corn and sugar cane known as Agri-Business
Management and Training Project was discontinued due to losses incurred while carrying on the
said project. Some CMU personnel, among whom were the complainants, were laid-off when
this project was discontinued. The CMU later launched a self-help project called CMU-Income
Enhancement Program (CMU-IEP) to develop unutilized land resources, mobilize and promote
the spirit of selfreliance, provide socio-economic and technical training in actual field project
implementation and augment the income of the faculty and the staff. The one-year contracts
expired on June 30, 1988. Some contracts were renewed. Those whose contracts were not
renewed were served with notices to vacate. The non-renewal of the contracts, the
discontinuance of the rice, corn and sugar can project, the loss of jobs due to termination or
separation from the service and the alleged harassment by school authorities, all contributed to,
and precipitated the filing of, the complaint.
ISSUES:
1.) Whether or not the DARAB has jurisdiction to hear and decide Case No. 005 for
Declaration of Status of Tenants and coverage of land under the CARP.
2.) Whether or not respondent Court of Appeals committed serious errors and grave abuse of
discretion amounting to lack of jurisdiction in dismissing the Petition for Review on Certiorari
and affirming the decision of DARAB.
RULING:
DARAB JURISDICTION LIMITED ONLY TO MATTERS INVOLVING
IMPLEMENTATION OF CARP. Under Section 4 and Section 10 of R.A. 6657, it is crystal
clear that the jurisdiction of the DARAB is limited only to matters involving the implementation
of the CARP. More specifically, it is restricted to agrarian cases and controversies involving
lands falling within the coverage of the aforementioned program. It does not include those which
are actually, directly and exclusively used and found to be necessary for, among such purposes,
school sites and campuses for setting up experimental farm stations, research and pilot
production centers, etc.Consequently, the DARAB has no power to try, hear and adjudicate the
case pending before it involving a portion of the CMU's titled school site, as the portion of the
CMU land reservation ordered segregated is actually, directly and exclusively used and found by
the school to be necessary for its purposes.
SEGREGATING SOME HECTARES OF LAND WITHOUT FINDING THAT
COMPLAINANTS ARE TENANTS: GRAVE ABUSE OF DISCRETION. Where the quasi-
judicial body finds that the complainants/petitioners are not entitled to the rights they are
demanding, it is an erroneous interpretation of authority for that quasi-judicial body to order
private property to be awarded to future beneficiaries. The order segregating 400 hectares of the
CMU land was issued on a finding that the complainants are not entitled as beneficiaries, and on
an erroneous assumption that the CMU land which is excluded or exempted under the law is
subject to the coverage of the CARP. Going beyond what was asked by the complainants who
were not entitled to the relief prayed for, constitutes a grave abuse of discretion because it
implies such capricious and whimsical exercise of judgment as is equivalent to lack of
jurisdiction.
NEITHER DARAB OR COURT OF APPEALS HAS RIGHT TO PASS UPON NEEDS
OF SCHOOL. As to the determination of when and what lands are found to be necessary for
use by the CMU, the school is in the best position to resolve and answer the question and pass
upon the problem of its needs in relation to its avowed objectives for which the land was given to
it by the State. Neither the DARAB nor the Court of Appeals has the right to substitute its
judgment or discretion on this matter, unless the evidentiary facts are so manifest as to show that
the CMU has no real need for the land.
The evidence is sufficient to sustain a finding of grave abuse of discretion by respondents Court
of Appeals and DAR Adjudication Board. The Court declared the decision of the DARAB and
the Court of Appeals as null and void and hereby order that they be set aside, with costs against
the private respondents.
Mendoza, Roland Joseph C.
2015-087212
Labor Arbiter Benedict Kato

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