The Supreme Court has ruled that lands classified as non-agricultural in zoning ordinances approved before June 15, 1988, are exempt from the Comprehensive Agrarian Reform Program (CARP). This decision underscores the importance of land classification prior to the enactment of CARP, providing landowners with a basis to seek exemption from agrarian reform coverage. However, the Court emphasized that substantial evidence is necessary to prove that the lands in question fall within the non-agricultural classification to qualify for this exemption.

From Farms to Factories? Zoning Laws vs. Agrarian Reform

The case of Remigio D. Espiritu and Noel Agustin vs. Lutgarda Torres del Rosario revolved around a dispute over landholdings in Angeles City, Pampanga. Lutgarda Torres del Rosario sought to exempt her land from CARP coverage, claiming it had been reclassified as non-agricultural before the enactment of Republic Act No. 6657, the Comprehensive Agrarian Reform Law. The farmers, led by Remigio Espiritu, contested this, arguing that the land was still classified as agricultural under existing zoning ordinances. This conflict brought to the forefront the question of how prior land classifications interact with agrarian reform laws and the extent of evidence required to prove such classifications.

Del Rosario’s application for exemption hinged on an alleged reclassification of Lot Nos. 854 and 855 in Barangays Margot and Sapang Bato, Angeles City, from agricultural to non-agricultural or industrial lots in March 1980. This claim was initially supported by an order from then Secretary of Agrarian Reform Roberto M. Pagdanganan. However, this order was later revoked by Secretary Nasser C. Pangandaman based on certifications from the Housing and Land Use Regulatory Board (HLURB) indicating that the landholdings were within an agricultural zone. The legal framework governing this issue is rooted in Republic Act No. 6657, which aims to redistribute agricultural lands to landless farmers. However, the law does not cover lands already classified for non-agricultural uses before its enactment.

The Court of Appeals initially sided with Del Rosario, citing a denial of due process due to misdirected notices and questioning the authority of Deputy Executive Secretary Manuel B. Gaite. However, the Supreme Court reversed this decision, emphasizing that Del Rosario was not deprived of due process because she was able to file a motion for reconsideration, which was considered on its merits. The Supreme Court referenced the case of Department of Agrarian Reform v. Samson, clarifying that due process in administrative proceedings requires only a fair opportunity to explain one’s side or seek reconsideration. Moreover, the Court highlighted that Deputy Executive Secretary Gaite’s decision was presumed valid and effective, as he was considered a de facto officer at the time, and no evidence was presented to prove that his actions were ultra vires.

Building on this principle, the Supreme Court clarified that the official acts of a de facto officer are valid, protecting the public’s dealings with individuals whose authority appears to emanate from the State. This legal principle ensures stability and reliability in governmental functions. Further solidifying its stance, the Court invoked the presumption of regularity in official acts, stating that this presumption prevails unless rebutted by clear and convincing evidence of irregularity or failure to perform a duty. This places a significant burden on parties seeking to challenge official actions.

In resolving the central issue, the Supreme Court considered the land classifications and zoning ordinances applicable to the property. The court examined the interplay between local government authority to reclassify land and the Department of Agrarian Reform’s mandate to implement agrarian reform. Citing Heirs of Luna v. Afable, the Court affirmed the power of local governments to reclassify agricultural lands into non-agricultural lands through zoning ordinances. However, the Court also emphasized that for such reclassifications to exempt land from CARP coverage, the zoning ordinance must have been approved by the Housing and Land Use Regulatory Board (HLURB) before June 15, 1988.

The court referenced Department of Justice Opinion No. 44, which clarified that the Department of Agrarian Reform’s authority to approve or disapprove land conversions applies only to conversions made on or after June 15, 1988. This opinion became the basis for subsequent DAR issuances, stating that prior conversion clearances were unnecessary for lands classified as non-agricultural before the enactment of Republic Act No. 6657. The Court found that both the Department of Agrarian Reform and the Office of the President had determined the lands in question to be agricultural based on certifications from the HLURB and ocular inspections. The evidence showed that the land was classified as agricultural in the 1978 zoning ordinance and that the area remained predominantly planted with sugarcane and corn.

Ultimately, the Supreme Court granted the petition, reinstating the orders of the Department of Agrarian Reform and the Office of the President, which had classified the land as agricultural and subject to CARP coverage. This decision underscores the importance of establishing the land’s classification prior to June 15, 1988, and the need for substantial evidence to support claims of non-agricultural use. The Court’s ruling reinforces the presumption of regularity in official acts and the principle that administrative agencies’ factual findings are generally accorded great respect and finality. This precedent is critical for landowners seeking to exempt their properties from agrarian reform laws, as it sets a high evidentiary bar and emphasizes the significance of historical land classifications.

FAQs

What was the key issue in this case?	The key issue was whether the land in question was classified as non-agricultural before the enactment of the Comprehensive Agrarian Reform Law (CARP) in 1988, which would exempt it from CARP coverage.
What evidence is needed to prove land reclassification?	Substantial evidence is needed, such as zoning ordinances approved by the Housing and Land Use Regulatory Board (HLURB) before June 15, 1988, and certifications from relevant government agencies.
What is the significance of Department of Justice Opinion No. 44?	DOJ Opinion No. 44 clarifies that the Department of Agrarian Reform’s authority to approve or disapprove land conversions applies only to conversions made on or after June 15, 1988.
What does due process mean in administrative proceedings?	Due process in administrative proceedings means providing a fair and reasonable opportunity to explain one’s side or seek reconsideration of the action or ruling complained of.
Who has the power to reclassify agricultural land?	Local government units have the power to reclassify agricultural lands into non-agricultural lands through zoning ordinances, subject to approval by the HLURB.
What is a ‘de facto’ officer?	A ‘de facto’ officer is one who derives appointment from one having colorable authority, and whose appointment is valid on its face; the acts of a de facto officer are valid for all purposes as those of a de jure officer.
What is the presumption of regularity?	The presumption of regularity means that official acts of public officers are presumed to have been performed in the regular course of business and are valid unless proven otherwise by clear and convincing evidence.
What was the HLURB’s role in this case?	The Housing and Land Use Regulatory Board (HLURB) was the agency whose certifications were used to determine the land’s classification, as their approval of zoning ordinances is critical for exemption from CARP.
What was the impact of the Court of Appeals decision?	The Court of Appeals initially sided with Del Rosario, but the Supreme Court reversed this decision, emphasizing that Del Rosario was not deprived of due process because she was able to file a motion for reconsideration.

This case clarifies the legal standards for exempting land from CARP based on prior land classifications, emphasizing the importance of documented zoning ordinances and the presumption of regularity in official actions. The ruling provides a framework for landowners and agrarian reform beneficiaries to understand their rights and obligations under the law.

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: REMIGIO D. ESPIRITU VS. LUTGARDA TORRES DEL ROSARIO, G.R. No. 204964, October 15, 2014