Angalilan vs Office of the President Mar. 26, 2010, GR 180471, 616 SCRA 633

Fact:  Petitioner filed an Application and/or Petition for Exclusion/Exemption from Comprehensive Agrarian Reform Program (CARP) Coverage of its landholding with the MARO of the DAR. It averred that, in 1982, the Sangguniang Bayan of Batangas City classified the subject landholding as reserved for residential under a zoning ordinance (1982 Ordinance), which was approved by the Human Settlement Regulatory Commission. It further alleged that, the Sangguniang Panglungsod of Batangas City approved the City Zoning Map and Batangas Comprehensive Zoning and Land Use Ordinance (1994 Ordinance), reclassifying the landholding as residential-1. Petitioner thus claimed exemption of its landholding from the coverage of the CARP. In support of its application, petitioner submitted a certification of Zoning Administrator Delia O. Malaluan. DAR Secretary Ernesto Garilao issued an Order denying petitioner’s application for exemption. The DAR Secretary noted that, as of February 15, 1993, the Alangilan landholding remained agricultural, reserved for residential. It was classified as residential-1 only on December 12, 1994 under Sangguniang Panlalawigan Resolution No. 709, series of 1994. Clearly, the subject landholding was still agricultural at the time of the effectivity of Republic Act No. 6657, or the Comprehensive Agrarian Reform Law (CARL), on June 15, 1988. The qualifying phrase reserved for residential means that the property is still classified as agricultural, and is covered by the CARP. The DAR Secretary disposed the application for exemption involving seventeen (17) parcels of land with an aggregate area of 23.9258 hectares was GRANTED insofar as the 4.9123 hectares and DENIED with respect to the 17.4892 subject to the payment of disturbance compensation to qualified tenants, if any there be. Petitioner moved for reconsideration of the Order to DAR, OP and CA but all of its appeal was denied, hence the appeal.

Issue: Where the DAR Secretary have jurisdiction in denying the petition for exemption in the CARP

Held: Yes, The exclusive jurisdiction to classify and identify landholdings for coverage under the CARP is reposed in the DAR Secretary. The matter of CARP coverage, like the instant case for application for exemption, is strictly part of the administrative implementation of the CARP, a matter well within the competence of the DAR Secretary. The power to determine whether a property is subject to CARP coverage lies with the DAR Secretary pursuant to Section 50 of R.A. No. 6657. Verily, it is explicitly provided under Section 1, Rule II of the DARAB Revised Rules that matters involving strictly the administrative implementation of the CARP and other agrarian laws and regulations, shall be the exclusive prerogative of and cognizable by the Secretary of the DAR. Finally, it is well settled that factual findings of administrative agencies are generally accorded respect and even finality by this Court, if such findings are supported by substantial evidence. The factual findings of the DAR Secretary, who, by reason of his official position, has acquired expertise in specific matters within his jurisdiction, deserve full respect and, without justifiable reason, ought not to be altered, modified, or reversed.


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