The Supreme Court ruled that Republic Act No. 8532 (R.A. 8532) extended the term for implementing the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657 (R.A. 6657). This means the Department of Agrarian Reform (DAR) had the authority to issue Notices of Coverage (NOC) and Acquisition (NOA) after June 15, 1998, beyond the initial 10-year implementation period of CARP. This decision validates NOCs and NOAs issued after the original deadline, ensuring the continuation of land distribution to qualified beneficiaries under the CARP, and upholding the State’s commitment to agrarian reform.
Agrarian Reform Timeline: Did R.A. 8532 Revive DAR’s Authority?
The case revolves around a parcel of land owned by Woodland Agro-Development, Inc. (Woodland). The DAR issued an NOC and NOA to place a portion of Woodland’s land under CARP coverage. Woodland challenged these notices, arguing that R.A. 6657 had expired on June 15, 1998, and that R.A. 8532 did not extend DAR’s authority to acquire land for distribution. The central legal question is whether R.A. 8532 authorized the DAR to issue NOCs and NOAs after the original 10-year implementation period of CARP, which was set to expire on June 15, 1998.
Woodland argued that Section 5 of R.A. 6657 provided a strict 10-year period for CARP implementation, which had lapsed. They further contended that R.A. 8532, which amended the funding provisions of R.A. 6657, did not extend the DAR’s authority to acquire lands. In contrast, the DAR relied on Department of Justice (DOJ) Opinion No. 009, Series of 1997, which stated that the 10-year period was merely a guideline for the DAR’s priorities and not a limitation on its authority. This opinion suggested that the timeline was directory rather than mandatory, allowing for flexibility in CARP implementation. The legal debate centered on interpreting the scope and effect of R.A. 8532 on the timeline for CARP implementation.
The Supreme Court anchored its decision on Article XIII, Section 4 of the 1987 Constitution, which mandates the State to undertake an agrarian reform program. This constitutional provision emphasizes the State’s commitment to distributing agricultural lands to landless farmers. The Court also cited Secretary of Agrarian Reform v. Tropical Homes, Inc., recognizing CARP as a “bastion of social justice” designed to redistribute land to the underprivileged. Building on these principles, the Court emphasized that the agrarian reform program must be faithfully implemented to achieve social justice. Therefore, the Court rejected Woodland’s argument that the DAR’s authority ceased after the 10-year period.
The Court scrutinized the language of Section 63 of R.A. 6657, which pertains to funding sources for CARP. As originally worded, Section 63 referred to the initial amount needed to implement “this Act for the period of ten (10) years upon approval hereof.” However, R.A. 8532 amended this section to state that “the amount needed to implement this Act until the year 2008 shall be funded from the Agrarian Reform Fund.” The Court interpreted the phrase “until the year 2008” as an unmistakable extension of the DAR’s authority to issue NOCs for acquiring and distributing private agricultural lands. This interpretation aligns with the legislative intent to provide continuous funding for the CARP’s objectives. In 2009, R.A. 9700 further extended the acquisition and distribution of agricultural lands until June 30, 2014.
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The Supreme Court emphasized that impeding the DAR’s ability to issue NOCs and NOAs after June 15, 1998, would frustrate the purpose of CARP. The agrarian reform program is designed to alleviate the lives of poor farmers and promote social justice. The Court also noted that R.A. 9700, entitled “An Act Strengthening the Comprehensive Agrarian Reform Program (CARP), Extending the Acquisition and Distribution of All Agricultural Lands…”, implicitly acknowledges that CARP was extended from 1998 to 2008 via R.A. 8532. Without the prior extension, R.A. 9700 could not have further extended the program.
FAQs
| What was the key issue in this case? | The key issue was whether R.A. 8532 authorized the DAR to issue Notices of Coverage and Acquisition after June 15, 1998, which was beyond the original 10-year implementation period of CARP. |
| What did the Regional Trial Court rule? | The RTC ruled that R.A. 8532 did not extend the acquisition of private lands beyond June 15, 1998, and nullified the DAR’s Notice of Coverage and Notice of Acquisition. |
| What was the basis of Woodland’s argument? | Woodland argued that R.A. 6657 provided a strict 10-year period for CARP implementation and that R.A. 8532 only amended the funding provisions. |
| What was the DAR’s argument? | The DAR argued, based on DOJ Opinion No. 009, that the 10-year period was merely a guideline and that R.A. 8532 extended the implementation of CARP. |
| What did the Supreme Court decide? | The Supreme Court ruled that R.A. 8532 extended the term for implementing CARP, validating the DAR’s authority to issue NOCs and NOAs after June 15, 1998. |
| What constitutional provision supported the Court’s decision? | Article XIII, Section 4 of the 1987 Constitution, which mandates the State to undertake an agrarian reform program, supported the Court’s decision. |
| How did R.A. 8532 affect Section 63 of R.A. 6657? | R.A. 8532 amended Section 63 of R.A. 6657 to extend the funding for CARP “until the year 2008,” which the Court interpreted as an extension of the DAR’s authority. |
| What is the significance of R.A. 9700 in this context? | R.A. 9700 further extended the acquisition and distribution of agricultural lands until June 30, 2014, building on the extension already provided by R.A. 8532. |
In conclusion, the Supreme Court’s decision in this case affirms the government’s commitment to agrarian reform by upholding the DAR’s authority to continue implementing CARP beyond the initial 10-year period. This ruling ensures that qualified farmers and farm workers have the opportunity to own the lands they till, promoting social justice and equitable distribution of agricultural resources.
For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.
Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Department of Agrarian Reform vs Woodland Agro-Development, Inc., G.R. No. 188174, June 29, 2015
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