Primary Holding
Sections 3(b), 11, 13, 16(d), 17, and 32 of R.A. No. 6657 were declared unconstitutional to the extent that they included livestock, poultry, and swine raising within the agrarian reform program, as such activities are not consistent with the constitutional intent of agrarian reform.
Background
Luz Farms, a corporation engaged in livestock and poultry raising, challenged certain provisions of R.A. No. 6657 arguing that livestock and poultry operations shouldn't be considered agricultural lands under agrarian reform laws. The petitioner claimed that the application of these provisions violated its property rights and due process.
History
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June 10, 1988: Comprehensive Agrarian Reform Law (R.A. No. 6657) was enacted.
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January 2 & 9, 1989: Department of Agrarian Reform issued rules and guidelines implementing the law, specifically covering livestock and poultry raisers.
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July 4, 1989: Petitioners’ initial request for a preliminary injunction was denied.
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August 24, 1989: Supreme Court granted injunctive relief pending resolution of the case.
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December 04, 1990: The Court decided the case, declaring questioned provisions unconstitutional.
Facts
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1.
Luz Farms contended that livestock, poultry, and swine raising are industrial rather than agricultural activities.
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2.
Land constitutes only a minimal portion of investments for such ventures, primarily used for housing, feed storage, and operational facilities.
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3.
The contested provisions required livestock and poultry farms to comply with land redistribution and profit-sharing schemes under agrarian reform law, despite significant distinctions between livestock farming and traditional crop-growing agriculture.
Arguments of the Petitioners
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1.
Luz Farms contended that livestock, poultry, and swine raising are industrial rather than agricultural activities.
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2.
Land constitutes only a minimal portion of investments for such ventures, primarily used for housing, feed storage, and operational facilities.
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3.
The contested provisions required livestock and poultry farms to comply with land redistribution and profit-sharing schemes under agrarian reform law, despite significant distinctions between livestock farming and traditional crop-growing agriculture.
Arguments of the Respondents
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1.
Livestock and poultry raising falls within the broad definition of "agriculture."
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2.
Section 3(b) of R.A. No. 6657 properly defines commercial farms to include livestock and poultry raising.
Issues
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1.
Whether portions of R.A. No. 6657, including livestock and poultry raising within its scope, are unconstitutional.
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2.
Whether the agrarian reform law's definition of "agricultural land" extends to lands used for livestock, poultry, and swine raising.
Ruling
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1.
The Court ruled that lands used for livestock, poultry, and swine raising are not agricultural lands within the purview of agrarian reform. The inclusion of such lands violates the Constitution due to the substantial distinctions between these industries and traditional farming.
Doctrines
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1.
Ordinary Meaning Rule: The Constitution’s reference to agrarian reform applies to lands primarily used for crop or tree farming, not industrial ventures such as livestock raising.
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2.
Equal Protection Clause: Treating industrial ventures like livestock farming the same as agricultural activities constitutes an invalid classification.
Key Excerpts
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1.
"There is simply no reason to include livestock and poultry lands in the coverage of agrarian reform."
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2.
"Land is not even a primary resource in this industry. The land input is inconsequential."
Precedents Cited
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1.
Association of Small Landowners of the Philippines, Inc. v. Secretary of Agrarian Reform: Landmark case affirming the constitutionality of R.A. No. 6657 but limited to traditional agricultural contexts.
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2.
J.M. Tuazon & Co. vs. Land Tenure Administration: Provided interpretative guidance on constitutional construction.
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3.
In re Guarina, 24 Phil. 37: Affirmed adherence to equal protection principles.
Statutory and Constitutional Provisions
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1.
Constitution (Article XIII, Section 4): Provision requiring agrarian reform to focus on lands tilled by farmers.
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2.
R.A. No. 6657, Sections 3(b), 11, 13, 16(d), 17, 32: Provisions challenged as unconstitutional.