KEICY M.

BENEDICTOS
2019119291
JD-2C

AGRARIAN LAW AND SOCIAL LEGISLATIONS

CASE DIGESTS (BATCH 2)

1. LUZ FARMS VS. THE HONORABLE SECRETARY OF DAR

192 SCRA 51

2. PNR VS. DEL VALLE

G.R. NO. L-29381
SEPTEMBER 30, 1968

3. KRIVENKO VS. REGISTER OF DEEDS

79 PHIL 461
NOVEMBER 15, 1947

4. MORTA VS. OCCIDENTAL

G.R. NO. 123417
JUNE 10, 1999

5. THE HEIRS OF JOSE JUANITE VS. COURT OF APPEALS

G.R. NO. 138016
JANUARY 30, 2002

6. HON. ANTONIO M. NUESA VS. CA

G.R. No. 132046
MARCH 6, 2002

7. ALMUETE VS. ANDRES

G.R. No. 122276
NOVEMBER 20, 2001

8. SPS. ATUEL, ET.AL., VS. SPS. BERNABE VALDEZ

G.R. NO. 139561
JUNE 10, 2003

9. CHICO VS. CA
348 PHIL. 37

10. LAGUNA ESTATES DEVELOPMENT CORPORATION VS. CA

G.R. NO. 119357
JULY 5, 2002
1. LUZ FARMS VS. THE HONORABLE SECRETARY OF DAR
192 SCRA 51

FACTS:
Raising of livestock, poultry and swine in its coverage are included in R.A. No.
6657 which was approved by the President of the Philippines on June 10, 1988.
Luz Farms, a corporation engaged in the livestock and poultry business and
together with others in the same business allegedly stands to be adversely affected by the
enforcement of Section 3(b), Section 11, Section 13, Section 16(d) and 17 and Section 32
of R.A. No. 6657.
Luz Farms argued that livestock or poultry raising is not similar with crop or tree
farming. That the land is not the primary resource in this undertaking and represents no
more than 5% of the total investments of commercial livestock and poultry raisers. That
the land is incidental but not the principal factor or consideration in their industry. Hence,
it argued that it should not be included in the coverage of RA 6657 which covers
“agricultural lands.

ISSUE:
Whether or not Sections 3(b), 11, 13 and 32 of R.A. No. 6657, insofar as the said
law includes the raising of livestock, poultry and swine in its coverage.

RULING:
No. Provisions of R.A. No. 6657 shall not include raising of livestock, poultry and
swine in its coverage.
Constitution stated that the State shall, by law, undertake an agrarian reform
program founded on the right of farmers and regular farmworkers, who are landless, to
own directly or 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 such priorities and
reasonable retention limits as the Congress may prescribe, taking into account ecological,
developmental, or equity considerations, and subject to the payment of just
compensation. In determining retention limits, the State shall respect the rights of small
landowners. The State shall further provide incentives for voluntary land-sharing.
The meaning of the word "agricultural," clearly show that it was never the
intention of the framers of the Constitution to include livestock and poultry industry in
the coverage of the constitutionally-mandated agrarian reform program of the
Government. In construing constitutional provisions which are ambiguous or of doubtful
meaning, the courts may consider the debates in the constitutional convention as
throwing light on the intent of the framers of the Constitution.
Hence, Provisions of R.A. No. 6657 shall not include raising of livestock, poultry
and swine in its coverage.
2. PNR VS. DEL VALLE
G.R. NO. L-29381
SEPTEMBER 30, 1968

FACTS:
Philippine National Railways, government-owned corporation, is a registered
owner of three (3) strips of land with a uniform width of 30 meters adjoining one another
longitudinally, the same being part of its railroad right of way running from Manila to
Legazpi. These strips of land lie within the municipalities of Oas and Polangui, Province
of Albay.
PNR draws earth from these sides to fill up the railroad track but the portions of
these lands not actually occupied had been a source of trouble. People occupied them;
they reap profits therefrom. Disputes among those desiring to occupy them cropped up. It
is on the face of all these that, with adequate provisions to safeguard railroad
operations, PNR adopted temporary rules and regulations which is to lease such
premises temporarily.
PNR awarded the portions of the three strips of land aforementioned to
petitioner Pantaleon Bingabing for a period of three (3) years and under conditions
hereinbefore set forth.
Bingabing, however, failed to take possession because
respondent Pampilo Doltz was occupying the land, had a house thereon and
planted palay on the other portions thereof enforcing that such land is an agricultural land
and properly cognizable by the Court of Agrarian Relations.

ISSUE:
Whether or not the strips of land owned by Philippine National Railways (PNR)
which are on both sides of its railroad track, and are part of its right of way for its railroad
operations but temporarily leased, are agricultural lands.

RULING:
No. The strips of land owned by Philippine National Railways (PNR) which are
on both sides of its railroad track, and are part of its right of way for its railroad
operations but temporarily leased, are not agricultural lands.
Definitions of “agricultural land” under Section 166(1) of the Agricultural
Tenancy Act and Agricultural Land Reform Code does not resonates on the criteria land
in this case.
It is obvious then that under the law, the land here in controversy does not fit into
the concept of agricultural land. PNR cannot devote it to agriculture because by its own
charter, Republic Act 4156, PNR cannot engage in agriculture.
Hence, The strips of land owned by Philippine National Railways (PNR) which
are on both sides of its railroad track, and are part of its right of way for its railroad
operations but temporarily leased, are not agricultural lands.
3. KRIVENKO VS. REGISTER OF DEEDS
79 PHIL 461
NOVEMBER 15, 1947

FACTS:
Alenxander A. Kriventor, an alien, bought a residential lot from the Magdalena
Estate, Inc. The registration of the said residential lot was interrupted by the war, thus, he
sought to accomplish said registration but was denied by the register of deeds of Manila
on the ground that, being an alien, he cannot acquire land in this jurisdiction.

ISSUE:
Whether or not an alien may acquire residential lots in the Philippines.

RULING:
No. Under the Constitution, aliens may not acquire private or public agricultural
lands, including residential lands.
Article XIII. Conservation and utilization of natural resources.
"Section 1. All agricultural, timber, and mineral lands of the public domain, waters,
minerals, coal, petroleum, and other mineral oils, all forces of potential energy, and other
natural resources of the Philippines belong to the State, and their disposition,
exploitation, development, or utilization shall be limited to citizens of the Philippines, or
to corporations or associations at least sixty per centum of the capital of which is owned
by such citizens, subject to any existing right, grant, lease, or concession at the time of
the inauguration of the Government established under this Constitution. Natural
resources, with the exception of public agricultural land, shall not be alienated, and no
license, concession, or lease for the exploitation, development, or utilization of any of the
natural resources shall be granted for a period exceeding twenty-five years, renewable for
another twenty-five years, except as to water rights for irrigation, water supply, fisheries,
or industrial uses other than the development of water 'power' in which cases beneficial
use may be the measure and the limit of the grant."
Sec. 1, Art 13 of the Constitution talks about the conservation and utilization of
natural resources. The said provision embraces all lands of any kind of the public domain.
Its purpose is to establish a permanent and fundamental policy for the conservation and
utilization of all natural resources of the nation. Although it mentions agricultural, timber,
and mineral lands, the court held that in determining whether a parcel of land is
agricultural, the test is not only whether it is actually agricultural, but also its
susceptibility to cultivation for agricultural purposes. Hence, “public agricultural land”
was construed as referring to those lands that were not timber or mineral. Therefore, it
includes residential lands.
Furthermore, the lands are for the conservation of the national patrimony, what is
important is the nature or class of the property regardless of whether it is owned by the
State or by its citizens.
Hence, an alien cannot acquire residential lots in the Philippines.
4. MORTA VS. OCCIDENTAL
G.R. NO. 123417
JUNE 10, 1999

FACTS:
A complaint was filed by Jaime Morta and Purificacion Padilla against Jaime
Occidental, Atty. Mariano Baranda, and Daniel Corral for allegedly gathering pili nuts,
anahaw leaves, and coconuts from their respective land and destroying their banana and
pineapple plants. However, Occidental claimed that he was a tenant of the actual owner
of the land, Josefina Baraclan, and that Morta and Padilla were not actually the owners of
the land in question.
Occidental claim that Morta is not a tenant of either Jaime Occidental or Josefina
Opiana-Baraclan, as shown by the MARO certification. They argue that the civil actions
for damages are not tenancy-related, and that Morta also claimed that he is the owner of
the land hence, are properly cognizable by the trial court, not the DARAB.

ISSUE:
Whether or not the subject case is within DARAB jurisdiction.

RULING:
No. Since there is a dispute in this case as to who is the rightful owner of the land,
The issue of ownership cannot be settled by the DARAB since it is definitely outside its
jurisdiction. Whatever findings made by the DARAB regarding the ownership of the land
are not conclusive to settle the matter.

For DARAB to have jurisdiction over a case, there must exist a tenancy
relationship between the parties. In order for a tenancy agreement to take hold over a
dispute, it would be essential to establish all its indispensable elements, to wit: 1) that the
parties are the landowner and the tenant or agricultural lessee; 2) that the subject matter
of the relationship is an agricultural land; 3) that there is consent between the parties to
the relationship; 4) that the purpose of the relationship is to bring about agricultural
production; 5) that there is personal cultivation on the part of the tenant or agricultural
lessee; and 6) that the harvest is shared between the landowner and the tenant or
agricultural lessee. These are not present in this case.
Hence, the subject case is not within DARAB jurisdiction.
5. THE HEIRS OF JOSE JUANITE VS. COURT OF APPEALS
G.R. NO. 138016
JANUARY 30, 2002

FACTS:
Separate portions of the land owned by spouses Edilberto and Felisa Romero in
Alegria, Surigao del Norte was sold on different dates to certain Efren Pania, Macario
Sanchez and Pio Yonson.
Claiming to be the agricultural tenants of the land in question, Jose Juanite (now
deceased) and his wife, Nicolasa O. Juanite, filed a complaint with the Provincial
Agricultural Reform Adjudication Board (PARAB), Department of Agrarian Reform
(DAR), against the spouses Edilberto and Felisa Mercado and their vendees above-named
for the cancellation of the sales adverted to and for the Juanites to exercise their right of
redemption pursuant to RA No. 3844, 2 section 12.
"Edilberto Romero, Et Al., as defendants, filed their answer with special and
affirmative defenses. They alleged that the Romeros, being the owners of the property,
had the perfect right to sell any portion thereof to any person. They strongly denied the
allegation of the Juanites that the latter were their tenants.

ISSUE:
Whether or not the petitioners were tenants of Spouses Romero as to entitle them
to the right of redemption.

RULING:
Yes. petitioners were tenants of Spouses Romero entitling them to the right of
redemption.
Based on the pieces of evidence a) certification of 28 persons to the effect that
spouses Juanite had been working on the land as tenants;
b) in the deed of absolute sale signed by Edilberto Romero as vendor, he stated that
spouses Juanite were his tenants; c) the spouses Juanite had been in possession and
cultivating the land since 1969, gathered by PARAB, it correctly declared the petitioners
to be tenants.
Though it does not comply with all the essential requisites of a tenancy
relationship however the landowners’ admission that petitioners were tenants on the
subject landholding, the element of "sharing harvest" is assumed as a factual element in
that admission.
Hence, petitioners were tenants of Spouses Romero as to entitling them to the
right of redemption.
6. HON. ANTONIO M. NUESA VS. CA
G.R. No. 132046
MARCH 6, 2002

FACTS:
Secretary of Agrarian Reform issued an "Order of Award" in favor of Jose
Verdillo over two (2) parcels of agricultural land, Lots 1932 and 1904 of the Buenavista
Estate, San Ildefonso, Bulacan, covering 14,496 and 19,808 square meters, respectively,
under certain conditions.
After twenty-one years, private respondent filed an application with the Regional
Office of the Department of Agrarian Reform for the purchase of said lots claiming that
he had complied with the conditions set forth in the Order.
Restituto Rivera, herein petitioner, filed a letter of protest against private
respondent claiming that contrary to the manifestation of private respondent, it is
petitioner who had been in possession of the land and had been cultivating the same.
Petitioner had filed his own application for said parcels in opposition to that of private
respondent.
In the investigation, it was undoubtedly established that Lots 1932 (pt.) and 1904,
Psd-52045, were in possession/cultivation of tenants or other persons exclusive of Jose
Verdillo.It is crystal clear that Jose Verdillo has culpably violated the terms and
conditions of the Order of Award issued in his favor for lots covered thereby.
Regional Director of DAR, Antonio M. Nuesa hereby issued cancelling Order of
Award dated May 25, 1972 issued in favor of Jose Verdillo for Lot 1932 (pt.) and Lot
1904, Psd-52045, Buenavista Estate, for violation of the rules and regulations pertaining
to the disposition of lots in landed estates and forfeiting whatever payments made by him
on account thereof in favor of the government. Accordingly, the subject lots are hereby
declared vacant and open for disposition in favor of qualified applicant.
DARAB Provincial Adjudicator, however, reverse the order of DAR.

ISSUE:
Whether or not the subject case falls under the jurisdiction of DARAB.

RULING:
No. The subject case does not fall under the jurisdiction of DARAB. The
revocation by the Regional Director of DAR of the earlier Order of Award by the
Secretary of Agriculture falls under the administrative functions of the DAR.
P.D. 946 provides that matters involving the administrative implementation of the
transfer of the land to the tenant-farmer under P.D. No. 27 and amendatory and related
decrees, orders, instructions, rules and regulations, shall be exclusively cognizable by the
Secretary of Agrarian Reform, including: issuance, recall or cancellation of certificates of
land transfer in cases outside the purview of P.D. No. 816.
Here, petitioner and private respondent had no tenurial, leasehold, or any agrarian
relations whatsoever that could have brought this controversy between them which leave
DARAB no jurisdiction over the controversy and should not have taken cognizance of
private respondent's petition in the first place.
7. ALMUETE VS. ANDRES
G.R. No. 122276
NOVEMBER 20, 2001

FACTS:
A parcel of agricultural land located at San Vicente, Angadanan, Isabela,
measuring approximately 72,587 square meters was awarded by the then National
Resettlement and Rehabilitation Administration (NARRA) to petitioner Rodrigo
Almuete. Since then, Rodrigo Almuete exercised exclusive possession of the property,
cultivating it and planting thereon narra, fruit trees, rice, corn and legumes. For some
twenty-two (22) years, Rodrigo Almuete and his family farmed the subject property
peacefully and exclusively.
However, an Agrarian Reform Technologist filed a field investigation and
inspection report the whereabouts of the original awardee of the subject property,
Rodrigo Almuete, had waived all his rights as a NARRA settler due to his poor health
beyond his control and financial hardship. The actual occupant of the land is Marcelo
Andres since April 1967 to date.
As the result of the investigation, Director of the Ministry of Agrarian Reform
(MAR) in Tuguegarao, Cagayan, the award in favor of Rodrigo Almuete cancelled and
that the land be awarded to respondent Marcelo Andres. Consequently, Marcelo Andres
was allowed to file his homestead application.
Unaware that the NARRA award in his favor had been cancelled, Almuete and his
family, continued to cultivate and farm the subject property.
Marcelo Andres, entered the subject property, claiming exclusive right of
ownership and possession arguing that since the subject property was agricultural land
covered by a homestead patent, exclusive jurisdiction was with the Department of
Agrarian Reform Adjudication Board (or DARAB), not with the regular courts.

ISSUE:
Whether or not the subject case falls under the jurisdiction of DARAB.

RULING:
No. The action filed by petitioners before the trial court was for recovery of
possession and reconveyance of title. The issue to be resolved was who between
petitioner Rodrigo Almuete and respondent Marcelo Andres has a better right to the
subject property considering that both of them are awardees of the same property. No
juridical tie of landowner and tenant was alleged between petitioners and respondent, let
alone that which would so characterize the relationship as an agrarian dispute.
Hence, the subject case does not fall under the jurisdiction of DARAB.
8. SPS. ATUEL, ET.AL., VS. SPS. BERNABE VALDEZ
G.R. NO. 139561
JUNE 10, 2003

FACTS:
Atty. Manuel D. Cab, the registered owner of two parcels of land in Poblacion,
Sibagat, Agusan del Sur with an area of 125,804 square meters, donated the lot occupied
by the municipal building being traversed by the Butuan to Davao Road and adjacent to
the municipal building of Sibagat.
Cab allowed the Spouses Federico and Sarah Atuel ("Spouses Atuel") and the
Spouses George and Eliada Galdiano ("Spouses Galdiano") to occupy a 2,000-square
meter portion of the Cab Property. The Spouses Atuel and the Spouses Galdiano
constructed their respective houses on this 2,000-square meter lot ("Subject Lot")
Atuel, appointed Federico as administrator of the Cab Property who
recommended to Cab to lease a portion of the Cab Property to Valdez, his nephew.
Parties entered into "Lease of Improved Agricultural Land".
Accordingly, Valdez was identified as a tenant, and thus deemed to be the owner
of the land he cultivated. 
Cab filed with the DAR in Manila a petition for cancellation of Valdez’s
emancipation patent. Cab claimed that his property is not planted to rice and corn and that
Valdez is a civil law lessee, not a tenant.
Spouses Valdez filed a complaint 9 for "Recovery of Possession with Damages"
with the DARAB in Malaybalay, Bukidnon against the Spouses Atuel and the Spouses
Galdiano.

ISSUE:
Whether or not the subject case falls under the jurisdiction of DARAB.

RULING:
No. DARAB’s lack of jurisdiction to take cognizance of the present case.
The issue to be resolved is who between the Spouses Valdez on one hand, and the
Spouses Atuel and the Spouses Galdiano on the other, have a better right to possession of
the 2,000-square meter Subject Lot forming part of the PD 27 Land.
For the DARAB to acquire jurisdiction over the case, there must exist a tenancy
relations between the parties. Spouses Atuel and the Spouses Galdiano and the Spouses
Valdez have no tenurial, leasehold, or any agrarian relations whatsoever that will bring
this controversy within Section 3(d) of RA No. 6657. 
Specifically, the regional trial court exercises exclusive original jurisdiction "in all
civil actions which involve possession of real property."However, if the assessed value of
the real property involved does not exceed P50,000.00 in Metro Manila, and P20,000.00
outside of Metro Manila, the municipal trial court exercises jurisdiction over actions to
recover possession of real property. Moreover, the municipal trial court exercises
jurisdiction over all cases of forcible entry and unlawful detainer.
 Hence, the subject case does not fall under the jurisdiction of DARAB.

9. CHICO VS. CA
348 PHIL. 37

FACTS:
Petitioner filed, on 31 July 1992, an action for the recovery of possession of the
property against private respondents claiming to be the lawful owner of a lot located in
Sta. Barbara, Baliuag, Bulacan.
Petitioner claimed that private respondents were occupying a portion of the
adjudicated lot which he would need for his own personal use and that of his family but
that because private respondents, despite repeated demands, refused to vacate the
premises.
Respondent spouses assert that the true owners of the property in question,
namely, Don Rafael and Doña Salud Chico, were succeeded upon their death by their son
Delfin Chico; that private respondents had long been in lawful possession of the subject
parcel of land as tenants of the deceased spouses and their son to whom rentals had been
paid.
RTC rendered its decision sustaining the complaint and ordering private
respondents to vacate the subject lot and to surrender its possession to petitioner.
Private respondents initiated with the Court of Appeals a petition for certiorari to
annul and set aside the RTC decision for allegedly being void Private respondents
claimed that their tenancy relationship with the original owner was an agrarian dispute
cognizable exclusively by the Department of Agrarian Reform Adjudication Board
("DARAB"), pursuant to E.O No. 229 and No. 129-A and R.A. No. 6657, and that,
consequently, the decision of the trial court was a complete nullity for want of
jurisdiction.

ISSUE:
Whether or not the subject case falls under the jurisdiction of DARAB.

RULING:
No. The complaint filed by petitioner before the trial court is one for recovery of
possession, also known as accion publiciana, and it is this averment of the complaint that
has conferred jurisdiction on that court. 
In order for a tenancy relation to take serious hold over the dispute, it would be
essential to first establish all its indispensable elements and tt is not enough that these
requisites are alleged; these requisites must be shown in order to divest the regular court
of its jurisdiction in proceedings lawfully began before it wherein these conditions have
not been met in the case.
Hence, the subject case does not fall under the jurisdiction of DARAB and RTC
correctly rendered its decision ordering private respondents to vacate the subject lot and
to surrender its possession to petitioner.
10. LAGUNA ESTATES DEVELOPMENT CORPORATION VS. CA
G.R. NO. 119357
JULY 5, 2002

FACTS:
Hectares of agricultural land situated in Barangay Casile, Cabuyao, Laguna
belonging to the Sta. Rosa Realty Development Corporation was placed by the
Department of Agrarian Reform (DAR), through its adjudicatory arm, public respondent
DARAB, under the compulsory acquisition scheme of the Comprehensive Agrarian
Reform Program (CARP), and subsequently, Certificates of Land Ownership Award
(CLOA’s) were issued and award to farmers-beneficiaries, private respondents herein.
It appears that the aforesaid agricultural lands in Bgy. Casile, Cabuyao, Laguna
are isolated and/or separated from the rest of the municipality of Cabuyao, and the only
passage way or access road leading to said private respondents’ agricultural lands is the
privately owned road network situated within the premises of petitioners. Subject to
reasonable security regulations, the subject road network is open to the public.
But after private respondents were awarded the aforesaid agricultural lands under
the CARP Law, petitioners prohibited and denied private respondents from utilizing the
subject road network.
On motion by private respondents, DARAB issued an order directing the
unhampered entry and construction of support services coming from the national
government, and other provisions for the use and benefit of private respondents giving
them a right of way over the subject road network owned by petitioners.

ISSUE:
Whether or not the DARAB has jurisdiction to grant private respondents who are
beneficiaries of an agrarian reform program or tenants of adjoining landholdings a right
of way over petitioners’ network of private roads intended for their exclusive use.

RULING:
No. The DARAB has no jurisdiction over the case. For DARAB to have
jurisdiction over a case, there must exist a tenancy relationship between the parties. The
issue of a right of way or easement over private property without tenancy relations is
outside the jurisdiction of the DARAB and not an agrarian issue.
Hence, DARAB has no jurisdiction to grant private respondents who are
beneficiaries of an agrarian reform program or tenants of adjoining landholdings a right
of way over petitioners’ network of private roads intended for their exclusive use.