In the case of Roman Catholic Archbishop of Caceres v. Secretary of Agrarian Reform, the Supreme Court ruled that lands owned by the Church are not automatically exempt from agrarian reform. The Court emphasized that being a registered landowner, even with conditional donations restricting sale or transfer, makes the Archbishop subject to land redistribution under Republic Act No. 6657. This decision clarifies that the Comprehensive Agrarian Reform Law (CARL) applies broadly to agricultural lands, irrespective of the landowner’s title or restrictions, and that exemptions must be explicitly stated in the law.

When Faith and Land Reform Collide: Can Church Lands Be Exempted?

The Roman Catholic Archbishop of Caceres sought to exempt its lands from the Comprehensive Agrarian Reform Program (CARP), arguing that as a trustee for its followers, it was not the landowner contemplated by law. The Archbishop claimed that the lands, donated with specific prohibitions against sale or encumbrance, were held for charitable and religious purposes, thus exempting them from agrarian reform. The Department of Agrarian Reform (DAR) denied this claim, and the case eventually reached the Supreme Court, which had to determine whether the Archbishop’s role as trustee and the conditional nature of the land donations provided a basis for exemption from CARP.

The Supreme Court firmly rejected the Archbishop’s arguments, asserting that the law makes no distinction regarding the type of title held by the landowner. The Court underscored that the registered owner is considered the landowner for agrarian reform purposes, regardless of any internal arrangements or conditions placed on the land. In the words of the Court:

The laws simply speak of the ‘landowner’ without qualification as to under what title the land is held or what rights to the land the landowner may exercise. There is no distinction made whether the landowner holds ‘naked title’ only or can exercise all the rights of ownership.

The Court emphasized that introducing exceptions not explicitly stated in the law would undermine the goal of land redistribution. This ruling affirmed the state’s power to implement agrarian reform to promote social justice and equitable distribution of land resources.

Building on this principle, the Court dismissed the idea that the Archbishop could claim multiple retention rights on behalf of each beneficiary. The Court stated that neither Presidential Decree No. 27 nor Republic Act No. 6657 provides for a landowner to exercise more than one right of retention. To allow multiple retention rights would create a loophole that could effectively shield vast tracts of land from agrarian reform, frustrating the law’s intent. According to the Court:

Nothing in either law supports Archbishop’s claim to more than one right of retention on behalf of each cestui que trust. The provisions of PD 27 and RA 6657 are plain and require no further interpretation–there is only one right of retention per landowner, and no multiple rights of retention can be held by a single party.

The Court also addressed the issue of conditional donations and their impact on agrarian reform. The Archbishop argued that the restrictions on selling or transferring the land prevented him from being considered a landowner under the law. However, the Court cited Hospicio de San Jose de Barili, Cebu City v. Department of Agrarian Reform, where it was held that the compulsory nature of agrarian reform overrides such conditions. The Court clarified that agrarian reform is akin to a forced sale, where the transfer of land occurs by operation of law, regardless of the landowner’s consent or contractual restrictions. Therefore, restrictions imposed by donors do not exempt the land from agrarian reform coverage.

The Court further clarified that exemptions from agrarian reform are explicitly listed in Republic Act No. 6657 and do not include lands held by administrators or trustees. The Court emphasized the principle that express exceptions exclude all others, meaning that if a particular exemption is not explicitly mentioned in the law, it does not exist. Allowing additional exemptions based on the landowner’s status would undermine the broad application of agrarian reform and frustrate its social justice goals. The Court then stated:

Archbishop would claim exemption from the coverage of agrarian reform by stating that he is a mere administrator, but his position does not appear under the list of exemptions under RA 6657. His claimed status as administrator does not create another class of lands exempt from the coverage of PD 27 or RA 6657, and The Roman Catholic Apostolic Administrator of Davao, Inc. does not create another definition for the term ‘landowner.’

The Supreme Court’s decision reinforces the state’s commitment to agrarian reform as a tool for social justice. The Court recognized the revolutionary character of expropriation under agrarian reform and emphasized that this purpose must not be hindered by appending conditions to land donations or by donating land to a church. While acknowledging the charitable ideals of religious organizations, the Court asserted that they should not be used as vehicles for keeping land out of the hands of the landless. The law ensures that landowners, including religious institutions, receive just compensation for the land transferred, which can then be used for their respective missions.

FAQs

What was the central legal question in this case?	The key issue was whether lands owned by the Roman Catholic Archbishop of Caceres were exempt from the Comprehensive Agrarian Reform Program (CARP). The Archbishop argued that his role as trustee and the conditional nature of the land donations exempted the properties from land redistribution.
What did the Supreme Court decide?	The Supreme Court ruled against the Archbishop, holding that the lands were not exempt from CARP. The Court emphasized that the registered owner is considered the landowner for agrarian reform purposes, regardless of any internal arrangements or conditions placed on the land.
Can landowners claim multiple retention rights under CARP?	No, the Supreme Court clarified that neither Presidential Decree No. 27 nor Republic Act No. 6657 allows a landowner to exercise more than one right of retention. Allowing multiple retention rights would create a loophole that could frustrate the law’s intent.
Do restrictions on land donations exempt the land from CARP?	No, the Supreme Court held that restrictions on selling or transferring the land do not exempt it from agrarian reform. Agrarian reform is akin to a forced sale, where the transfer occurs by operation of law, regardless of the landowner’s consent or contractual restrictions.
Are there any exemptions from CARP?	Yes, Republic Act No. 6657 lists specific exemptions, such as lands used for parks, wildlife reserves, and national defense. However, the Supreme Court emphasized that these exemptions are exclusive, and any claim for exemption must fall within the explicitly listed categories.
What is the significance of this ruling?	This ruling reinforces the state’s commitment to agrarian reform as a tool for social justice. It clarifies that the law applies broadly to agricultural lands and prevents landowners from circumventing agrarian reform through creative legal arguments.
What happens to the landowner if the land is covered by CARP?	The landowner is entitled to just compensation for the land transferred under CARP. This compensation allows landowners, including religious institutions, to continue their missions and activities.
Does this ruling affect religious organizations?	The ruling clarifies that religious organizations are not exempt from agrarian reform unless their lands fall within the specific exemptions listed in the law. It ensures that religious organizations cannot be used as vehicles for keeping land out of the hands of the landless.

The Supreme Court’s decision in Roman Catholic Archbishop of Caceres v. Secretary of Agrarian Reform reaffirms the broad scope of agrarian reform in the Philippines. It underscores that the goals of social justice and equitable land distribution cannot be easily circumvented through conditional donations or claims of trusteeship. The ruling ensures that agrarian reform remains an effective tool for empowering landless farmers and promoting rural development.

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: Roman Catholic Archbishop of Caceres v. Secretary of Agrarian Reform, G.R. No. 139285, December 21, 2007