The Supreme Court ruled that an association claiming to represent farmers and fishermen does not automatically have the right to question land coverage decisions under the Comprehensive Agrarian Reform Program (CARP). The Court emphasized that for such an association to have legal standing, it must prove that its members are identified and registered qualified beneficiaries of the land in dispute. This decision clarifies the requirements for associations to represent their members in agrarian reform cases, ensuring that only those with a direct and substantial interest in the land can bring legal challenges.
From Sequestration to CARP: Who Can Claim the Land in Sitio Naswe?
The case revolves around a 34-hectare property in Barangay Ipag, Mariveles, Bataan, which was originally part of a larger 129.4227-hectare land owned by Anchor Estate Corporation. The Presidential Commission on Good Governance (PCGG) sequestered Anchor Estate’s properties after determining it was a dummy corporation of the late President Ferdinand E. Marcos. Respondent Tomas Tan emerged as the highest bidder for the 34-hectare property, and the sale was approved by both the PCGG and the Office of the President (OP). However, prior to the sale, a Notice of Coverage was issued over the entire 129.4227-hectare land under the CARP, targeting the 34 hectares for acquisition in 2000. This prompted the PCGG to request the Department of Agrarian Reform (DAR) to stop the CARP acquisition, which the DAR Secretary granted by lifting the Notice of Coverage.
The petitioner, Samahan ng Magsasaka at Mangingisda ng Sitio Naswe, Inc. (SAMMANA), an association of farmers and fishermen residing in the area, filed a petition with the DAR to revoke the order lifting the Notice of Coverage. SAMMANA claimed its members had been farming the land for years and depended on it for their livelihood. The DAR denied the petition, arguing that the property, being government-owned, was not subject to CARP. The OP affirmed the DAR’s decision, leading SAMMANA to appeal to the Court of Appeals (CA). The CA dismissed the appeal, holding that SAMMANA was not a real party in interest because it failed to prove its members were identified as CARP beneficiaries. The Supreme Court then reviewed the CA’s decision.
At the heart of the legal issue is the concept of a real party in interest. The Rules of Court define a real party in interest as “the party who stands to be benefited or injured by the judgment in the suit, or the party entitled to the avails of the suit.” This means the party must have a direct and substantial interest in the subject matter of the action, not merely an expectancy or future contingent interest. SAMMANA argued that as an association representing farmers and fishermen who have resided in the area for years, it had a sufficient interest to challenge the lifting of the Notice of Coverage. However, the Court disagreed, emphasizing that the right to form associations does not automatically confer the right to represent members in legal actions unless those members have a real and substantial interest in the outcome.
The Court cited several precedents to support its decision. In Fortich v. Corona, the Court held that mere recommendee farmer-beneficiaries were not real parties in interest because their interest was only an expectancy. Similarly, in Sumalo Homeowners Association of Hermosa, Bataan v. Litton, the Court rejected the petitioners’ claim as real parties in interest because they failed to prove they had been identified and registered as qualified CARP beneficiaries. In this case, SAMMANA failed to show that its members were identified and registered qualified beneficiaries of the subject land, had been awarded portions of it, or had been issued Certificates of Land Ownership Award (CLOAs). The Court noted that SAMMANA even admitted that the case folders of its members were not processed because of the DAR Secretary’s order lifting the Notice of Coverage.
The Court also addressed the argument that Republic Act (RA) No. 6657 allows farmers’ organizations to represent their members before the DAR. While the law does grant this right, the Court clarified that it must be harmonized with the requirement of a real and substantial interest. This means that while organizations can represent their members, those members must still have a direct and material interest in the subject matter of the action, not merely an expectancy. The Court further explained that being a “qualified beneficiary” under CARP is not enough to be considered a party in interest, as the beneficiaries must be approved awardees of CARP.
Furthermore, the Court highlighted the principle that social justice in land reform applies to landowners as well as farmers and farmworkers. The procedures for determining beneficiaries and grantees of lands covered under CARP ensure that only qualified, identified, and registered individuals acquire the lands, while also protecting landowners from losing their lands to usurpers and illegal settlers. Therefore, for land to be covered under CARP, two requisites must concur: first, the land must be covered by a Notice of Coverage; and second, the beneficiaries must be qualified and registered by the DAR, in coordination with the Barangay Agrarian Reform Committee (BARC). The absence of either of these elements undermines a claim for coverage.
The Court also emphasized that the DAR’s order lifting the Notice of Coverage had already attained finality. SAMMANA filed its petition to revoke the lifting of the Notice of Coverage more than four years after the order was issued. Under Executive Order (E.O.) No. 292, the applicable general law at the time, an agency’s decision becomes final and executory fifteen days after receipt by the adversely affected party unless an appeal or motion for reconsideration is filed. Since no motion for reconsideration or appeal was filed from the July 26, 2000 order, it lapsed to finality and could no longer be reviewed. The Court reiterated that administrative decisions must end sometime, and in the absence of any showing that the order was rendered without jurisdiction or with grave abuse of discretion, no court has the power to revive, review, change, or alter a final and executory judgment or decision.
FAQs
| What was the key issue in this case? | The key issue was whether an association of farmers and fishermen had the legal standing to question the lifting of a Notice of Coverage under the Comprehensive Agrarian Reform Program (CARP) on a parcel of land. The Supreme Court focused on the requirement for a real party in interest. |
| What is a “real party in interest”? | A real party in interest is someone who stands to directly benefit or be harmed by the outcome of a legal case. They must have a substantial and material interest in the subject matter, not just a possible or future interest. |
| Why did the Supreme Court rule against the association? | The Court ruled against the association because it failed to prove that its members were identified and registered as qualified beneficiaries of the land under CARP. Without this proof, the members’ interest in the land was considered merely an expectancy. |
| What is a Notice of Coverage under CARP? | A Notice of Coverage is a formal declaration that a particular piece of land falls under the Comprehensive Agrarian Reform Program (CARP) and is subject to acquisition and distribution to qualified beneficiaries. It initiates the process of land reform. |
| What is a Certificate of Land Ownership Award (CLOA)? | A CLOA is a title document issued to qualified beneficiaries of CARP, granting them ownership of the land they have been awarded. It signifies that the beneficiary has met all the requirements and is now the legal owner of the land. |
| Does RA 6657 allow associations to represent farmers? | Yes, RA 6657 allows farmer leaders and organizations to represent their members in proceedings before the Department of Agrarian Reform (DAR). However, this right is contingent on the members having a real and substantial interest in the case. |
| What is the role of the Barangay Agrarian Reform Committee (BARC)? | The BARC assists the DAR in identifying and registering qualified beneficiaries of CARP at the barangay level. They play a crucial role in ensuring that only eligible individuals are considered for land distribution. |
| What was the significance of the DAR order lifting the Notice of Coverage? | The DAR order lifting the Notice of Coverage effectively removed the land from CARP coverage, preventing it from being acquired and distributed to farmer beneficiaries. This order was a key point of contention in the case. |
| Why did the Court say the DAR’s order had attained finality? | The Court noted that the association filed its petition to revoke the DAR’s order more than four years after it was issued, and no motion for reconsideration was filed on time. Therefore, the order became final and unreviewable. |
In conclusion, the Supreme Court’s decision in this case clarifies the requirements for associations to represent their members in agrarian reform disputes. It underscores the importance of proving that the members are identified and registered qualified beneficiaries with a direct and substantial interest in the land. This ensures that the CARP process is fair and equitable, protecting the rights of both landowners and qualified beneficiaries.
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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: SAMAHAN NG MAGSASAKA AT MANGINGISDA NG SITIO NASWE, INC. VS. TOMAS TAN, G.R. No. 196028, April 18, 2016