Landbank Vs Araneta

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LANDBANK vs.

ARANETA, GR 161796

FACTS:
At the heart of the controversy is a large tract of land with an area of 1,645 hectares, more or less, which was
originally registered in the name of Alfonso Doronilla (Doronilla) under Original Certificate of Title (OCT) No.
7924 of the Rizal Registry. On June 21, 1974, then President Marcos issued Proclamation 1283, carving out a wide
expanse from the Watershed Reservation in Antipolo, Rizal and reserving the segregated area for town site
purposes, "subject to private rights, if any there be.

 In 1978, the OSG filed with the then CFI of Rizal an expropriation complaint against the Doronilla property.
Meanwhile, on 1979, Doronilla issued a Certification, copy furnished the Agrarian Reform Office, among other
agencies, listing seventy-nine (79) "bona fide planters" he allegedly permitted to occupy a portion of his land. On
1987 or nine (9) years after it commenced expropriation proceedings, the OSG moved for and secured the dismissal
of the expropriation case.

Earlier, or on March 15, 1983, J. Amado Araneta, now deceased, acquired ownership of the subject Doronilla
property by virtue of court litigation. A little over a week later, he had OCT No.7924 canceled and secured the
issuance of Transfer Certificate of Title (TCT) No. N-70860 in his name.

ISSUES: Jurisdiction of DAR and its Adjudicating Arm

RULING:
The DARAB has been created and designed to exercise the DAR’s adjudicating functions. And just like any quasi-
judicial body, DARAB derives its jurisdiction from law, specifically RA 6657, which invested it with adjudicatory
powers over agrarian reform disputes and matters related to the implementation of CARL.

As earlier discussed, the process of land reform covering the 1,266 hectares of the Araneta estate was not completed
prior to the issuance of Proclamation 1637. So the intervenors, with the exception of the 79 tenant-beneficiaries who
were granted CLTs, failed to acquire private rights of ownership under PD 27 before the effective conversion of the
Doronilla property to non-agricultural uses.  Hence, the Doronilla property, being outside of CARP coverage, is also
beyond DARAB’s jurisdiction.
 
          The OSG’s withdrawal of the expropriation suit on September 9, 1987 did not, automatically restore the
Doronilla property to its original classification nor did it grant DAR or DARAB the power or jurisdiction to order
the compulsory acquisition of the property and to place it under CARP.

And, as the CA aptly noted, the DOJ Secretary, through Opinion 181,  even advised the DAR Secretary that lands
covered by Proclamation 1637, having been reserved for town site purposes, are not deemed “agricultural lands”
within the meaning and intent of Sec. 3(c) of RA 6657 and, hence, outside the coverage of CARL . The
Secretary of Justice further stated that RA 6657 did not supersede or repeal Proclamations 1283 and 1637 and they
remain operative until now; their being town site reservations still remain valid and subsisting.  To clarify, a DOJ
opinion carries only a persuasive weight upon the courts.  However since this Court, in Natalia Realty, Inc., cited
with approval DOJ Opinion No. 181, such citation carries weight and importance as jurisprudence.  Be that as it
may, We recognize and apply the principles found in Natalia Realty, Inc. regarding the character of the Doronilla
property being converted to a townsite and, thus, non-agricultural in character.

WHEREFORE, the petitions are hereby partly DENIED. The CA Decision dated September 19,
2003, as effectively reiterated in its Resolution of January 22, 2004 and April 2, 2004, is
AFFIRMED with the modification that the 75 CLTs issued prior to the effectivity of Presidential
Proclamation No. 1283 on June 21, 1974 are declared legal and valid. The other CLTs, EPs,
CLOAs issued by DAR involving the subject property are hereby CANCELED and
NULLIFIED.
 The Land Bank and DAR are hereby ordered to COMPUTE the just compensation of the
land subject of the 75 CLTs and PAY the just compensation to the Estate of J. Amado Araneta.
No pronouncement as to cost.
SO ORDERED.

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