Pasong Bayabas Farmers Association, Inc. vs. Court of Appeals

Lands reclassified as residential by local government units and approved by competent authorities prior to the effectivity of Republic Act No. 6657 are outside the coverage of the Comprehensive Agrarian Reform Law and the jurisdiction of the DARAB, provided no tenancy relationship exists with the landowner.

In 1964, Lakeview Development Corporation (LDC) acquired a 75-hectare property in Carmona, Cavite, later transferred to respondent Credito Asiatic, Inc. (CAI). On May 30, 1976, the Municipal Council of Carmona approved a resolution allowing LDC to establish a low-cost housing project on the property. Subsequent approvals were secured from the National Housing Authority, the Bureau of Lands, and the Human Settlements Regulatory Commission. On July 3, 1979, Agrarian Reform Minister Conrado Estrella approved the conversion of 35.8 hectares of the property into a residential subdivision, finding it untenanted and not devoted to palay or corn. In 1987, when CAI attempted to develop the property, some occupants filed a civil case for damages, which was eventually dismissed based on compromise agreements where the occupants executed quitclaims and received donated lots. In 1992 and 1994, new groups of occupants, organized as the Pasong Bayabas Farmers Association, Inc. (PBFAI), petitioned for compulsory agrarian reform coverage and filed a complaint for maintenance of peaceful possession before the DARAB when CAI resumed development activities.

• Property Acquisition and Reclassification: LDC purchased the 75-hectare property in 1964, with titles later transferred to CAI in 1977. On May 30, 1976, the Municipal Council of Carmona approved Kapasiyahang Bilang 30, permitting the establishment of a low-cost housing project. The National Planning Commission and the Bureau of Lands approved the subdivision plan. On July 3, 1979, Agrarian Reform Minister Estrella approved the conversion of 35.8 hectares to residential use, finding the land untenanted, not devoted to palay or corn, and suitable for residential subdivision.
• Initial Resistance and Settlement: In 1987, occupants filed Civil Case No. BCV-87-13 against CAI to halt bulldozing activities. The case was dismissed in 1991 based on compromise agreements where CAI donated parcels of land to the plaintiffs, who in turn executed deeds of quitclaim and waiver over the portions they previously occupied.
• Subsequent Petitions for CARP Coverage: In 1992, seventeen individuals claiming to be farmers petitioned for compulsory coverage under RA 6657. In 1994, the PBFAI filed a similar petition. When CAI resumed survey and bulldozing activities in October 1995, the PBFAI filed a complaint for maintenance of peaceful possession with the DARAB.
• Execution of Quitclaims: During the pendency of the DARAB case, twenty-five of the thirty-seven complainant-members of the PBFAI executed separate deeds of quitclaim in favor of CAI, receiving varied sums of money in exchange for waiving their claims over the property.

• CARP Coverage: Petitioners contended that the property is agricultural land covered by RA 6657, emphasizing that the land was planted with fruit-bearing trees, which qualify as agricultural crops under the expanded coverage of the law.
• Invalid Reclassification: The 1976 municipal reclassification was ineffective absent approval from the HSRC/HLURB, as required by Executive Order No. 648.
• DAR Exclusive Authority: DAR possesses exclusive authority to reclassify and convert agricultural lands under Section 65 of RA 6657, a power not negated by the Local Government Code. The municipal reclassification was subject to DAR approval pursuant to DOJ Opinion No. 44, Series of 1990.
• Reversion of Land: The failure of the respondent to complete the housing project before June 15, 1988, reverted the property to agricultural land, requiring an exemption clearance under DAR Administrative Order No. 6, Series of 1994.

• Valid Reclassification: The property was validly reclassified by the Municipal Council of Carmona in 1976 pursuant to its authority under the Local Autonomy Act (RA 2264).
• No DAR Approval Required: Per DOJ Opinion No. 40, Series of 1990, DAR approval was unnecessary for reclassifications that occurred prior to the effectivity of RA 6657 on June 15, 1988.
• Agency Concurrence: Multiple government agencies, including the NHA, Bureau of Lands, HSRC, HLURB, and the Ministry of Local Government, found the property unsuitable for agriculture and approved its residential use.
• Absence of Tenancy: The individual petitioners are squatters or interlopers rather than tenants, depriving the DARAB of jurisdiction over the dispute.

• CARL Coverage: Whether the property subject of the suit is covered by Republic Act No. 6657.
• DARAB Jurisdiction: Whether the DARAB had original and appellate jurisdiction over the complaint.
• Cause of Action: Whether the petitioners-members of the PBFAI have a cause of action against the private respondent for possession and cultivation of the property.
• Res Judicata: Whether the dismissal of Civil Case No. BCV-87-13 bars the current complaint.

• CARL Coverage: The property is not covered by RA 6657. Long before the law took effect in 1988, the property had been reclassified and converted to residential land by the Municipal Council of Carmona, the Ministry of Agrarian Reform, the Bureau of Lands, and the HSRC. Lands previously converted to non-agricultural uses prior to the effectivity of CARL by government agencies other than the DAR are outside the ambit of the law. The DAR's own Administrative Order No. 6, Series of 1994, confirms that lands classified as non-agricultural before June 15, 1988, no longer need conversion clearance. Section 65 of RA 6657 applies only to conversions of lands placed under agrarian reform after the law's effectivity.
• DARAB Jurisdiction: The DARAB lacked jurisdiction over the complaint. Jurisdiction is determined by the averments of the complaint and the law at the time of filing. Because the land was residential, no agrarian dispute existed. Furthermore, the DARAB's jurisdiction requires a tenancy relationship between the parties. No such relationship was established; the occupants were either bound by quitclaims or found to be mere interlopers and farm helpers without the consent of the landowner.
• Cause of Action: No cause of action exists for the petitioners. The essential elements of a tenancy relationship—particularly consent of the landowner and sharing of harvests—were absent. The execution of quitclaims by a majority of the members further waived any possessory rights over the property.
• Res Judicata: The prior dismissal and the execution of deeds of quitclaim and waiver negated the existence of any tenancy relationship or right of possession, reinforcing the lack of cause of action and jurisdiction.

• Jurisdiction of Quasi-Judicial Bodies — The jurisdiction of a tribunal or quasi-judicial body over the subject matter is determined by the averments of the complaint and the law extant at the time of the commencement of the suit. All proceedings before a tribunal bereft of jurisdiction are null and void.
• Elements of Tenancy — For the DARAB to exercise jurisdiction, a tenancy relationship must exist, requiring: (1) the parties are the landowner and the tenant; (2) the subject matter is agricultural land; (3) there is consent; (4) the purpose is agricultural production; (5) there is personal cultivation by the tenant; and (6) the harvest is shared between the parties.
• Pre-CARL Land Reclassification — Lands reclassified as residential by local government units prior to the effectivity of RA 6657 are outside CARP coverage and do not require DAR conversion clearance. The power of local governments to reclassify lands to non-agricultural uses is not subject to DAR approval.

• "Indeed, lands not devoted to agricultural activity are outside the coverage of CARL. These include lands previously converted to non-agricultural uses prior to the effectivity of CARL by government agencies other than respondent DAR."
• "The power of the local government to convert or reclassify lands to residential lands to non-agricultural lands reclassified is not subject to the approval of the Department of Agrarian Reform."

• Natalia Realty, Inc. v. DAR — Followed. Established that lands previously converted to non-agricultural uses prior to CARL by government agencies other than the DAR are outside the coverage of the law.
• Fortich v. Corona — Followed. Held that local government units need not obtain DAR approval to convert or reclassify lands from agricultural to non-agricultural use.
• Province of Camarines Sur v. Court of Appeals — Followed. Reiterated the authority of local government units to reclassify lands without DAR approval.
• Monsanto v. Zerna — Applied. Enumerated the essential elements of a tenancy relationship, the absence of which deprives the DARAB of jurisdiction.

• Section 3(c), Republic Act No. 6657 — Defines agricultural lands as those devoted to agricultural activity and not classified as mineral, forest, residential, commercial, or industrial land. Applied to exclude the subject property, which had been classified as residential prior to the law's effectivity.
• Section 65, Republic Act No. 6657 — Vests the DAR with authority to approve conversions of agricultural lands to non-agricultural uses. Construed to apply only to lands placed under agrarian reform after the law's effectivity, not to lands already converted prior to June 15, 1988.
• Section 3, Republic Act No. 2264 (Local Autonomy Act) — Empowers municipal and city councils to adopt zoning and subdivision ordinances. Applied to validate the 1976 reclassification by the Municipal Council of Carmona.
• DAR Administrative Order No. 6, Series of 1994 — Provides that lands already classified as non-agricultural before June 15, 1988, no longer need any conversion clearance. Relied upon to confirm the property's exemption from CARP coverage.

Puno, Quisumbing, Austria-Martinez, and Tinga.