Heirs of Augusto Salas, Jr. v.

Cabungcal

G.R. No. 191545, March 29, 2017, 822 SCRA 1

Leonen, J.

Facts:

Augusto Salas Jr. was the registered owner of a vast tract of agricultural land
traversing five barangays namely, Pusil, Bulacnin, Balintawak, Marawoy, and
Inosluban—in Lipa City, Batangas.

Meanwhile, Cabungcal was one of the tenant farmers in Salas’ agricultural land
and one of the agrarian reform beneficiaries under the Comprehensive Agrarian
Reform Program. In the said agricultural land, the aggregate area estimates
roughly at 1.5 million square meters or an area of 148, 4354 hectares that covers
Lots 1 and 2.

Sometime in May 1987, Salas entered into an Owner-Contractor Agreement with

Laperal Realty Corporation (Laperal Realty) for the development, subdivision,
and sale of his land. Pursuant to that, Salas subdivided Lot 1 into Lots A to C under
Psd-04-0262541, and Lot 2 into Lots A to K under Psd-04-0262542. A total of 14
subdivided lots were titled in his name. Meanwhile, Cabungcal including other
respondents continued to farm on his land holdings.
When RA 6657 was signed into law, the landholdings of Salas were among those
contemplated for acquisition and distribution to qualified beneficiaries. The heirs
of Salas assailed the inclusion of their landholdings to the excemptions under RA
6657. The petition was denied and 14 lots were awarded to agrarian reform
beneficiaries, including Cabungcal.
The Estate of Salas claimed that the properties awarded had been re-classified as
nonagricultural prior to the effectivity of RA 6657.-
Issue:
Whether or not the re classification of the agricultural land as a farmlot
subdivision exempts the estate of Salas from the coverage of the Comprehensive
Agrarian Reform Program?
Held:
No. The Court held that the reclassification of Salas’ landholding into a
farmlot subdivision, although effected before Republic Act No.6657, has not
changed the nature of these agricultural lands. Thus, these lots were properly
subjected to compulsory coverage under the Comprehensive Agrarian Reform
Law. The award of landholdings to the farmers, including to Cabungcal is correct.