Central Mindanao University (CMU) v.

Department of Agrarian Reform

Facts:
A complaint was filed by the Bukidnon Free Farmers and Agricultural
Laborers Organization (BUFFALO) against the CMU as Tenants.

CMU is an agricultural education institution owned by the estate in Musuan,

Bukidnon. It started as a farm school but it later on expanded and was
transferred to Malaybalay, the capital of Bukidnon.

In the early 1960’s it was converted into a college with campus in Musuan
until it became Central Mindanao University which is still primarily an
agricultural university. President Garcia reserved a site for the future
campus of CMU which has 3,080 hectares and was registered and titled
under the name of CMU.

In 1960’s the student population of the school was less than 3,000. By
1988, it had 13,000 students. To cope with the increase in enrollment, it
expanded its education facilities.

The school tried to support itself by adopting a livelihood program called “

Kilusang Sariling Sikap Program” under which the land resources of the
university was leased to the faculty and employees for a low-land rice
project. The contract prohibited the faculties and their hired workers to
establish houses or live in the project area and to use the land as a
collateral for a loan. It was expressly stipulated that “ NO LANDLORD-
TENANT RELATIONSHIP” existed between the CMU and the faculty.

When Chua became the president of CMU he discontinued the agri-

business project due to losses. Later on, Dr. Chua launched a self-help
project called CMU-Income Enhancement Program (CMU-IEP) to develop
unutilized land resources and to provide socio-economic and technical
training for faculty and staff.

3-party memorandum agreement was made between CMU, CMU-

Integrated Development Foundation and groups of seldas (5 CMU
employees) to which CMU would provide 4 to 5 hectares of land to 1 selda
for 1 calendar year. The same terms and conditions applied in KSSP were
applied in the 3-party memorandum.
After 1 year some contracts were not renewed which caused the filing of
the present complaint.

DARAB found that the private respondents are not tenants and that the 400
hectares used by CMU for their self-help project is covered under CARP.

Issue:
Whether the DAR is correct in segregating the 400 hectares of CMU.

Ruling:
Private respondents are not landless peasants, there is no landlord-tenant
relationship between the CMU and its seldas, and the purpose why they
were allowed to occupy such land is to carry out certain university projects.
Once the contract expired, they became squatters.

The land questioned is based on the fact that the land was allegedly not
directly, actually and exclusively used as a school site for the same was
leased to Philippine Packing Corporation ( DEL MONTE Phils.). The
construction given by DARAB to Section 10 restricts the land area of CMU
to its present needs overlooking the growth of the university over the years
to come.

Moreover, the KSSP is a multidisciplinary applied research extension and

productivity program which means that its activities is still educational.
Furthermore, the land leased to Philippine Packing Corporation (DEL
MONTE Phils.) was leased long before the CARP was passed. It was not
just a lease but it is a “ MANAGEMENT AND DEVELOPMENT
AGREEMENT” which is a research program with the direct participation of
the faculty and students.

As to the determination of when and what the lands are found to be

necessary for use by the CMU, the school is in the best position to resolve
such question. The DARAB and the CA has no right to substitute its
judgment or discretion unless there are evidences which would show that
CMU had no need of its land.

DARAB had no power to adjudicate the case pending before it involving

CMU since the land was reserved for it to be used as a School. The order
segregating 400 hectares from CMU by DARAB is erroneous for it is
exempted from the coverage of CARP.