GR 170623; (July, 2010) (Digest)
G.R. No. 170623 ; July 9, 2010
A.Z. ARNAIZ REALTY, INC., represented by CARMEN Z. ARNAIZ, Petitioner, vs. OFFICE OF THE PRESIDENT, et al., Respondents.
FACTS
Petitioner A.Z. Arnaiz Realty, Inc. filed a petition before the DAR Regional Director for the exclusion of its three parcels of land in Masbate, with an aggregate area of 843 hectares, from the coverage of the Comprehensive Agrarian Reform Program (CARP). The grounds for exclusion were that the lands had been devoted to cattle-ranching since time immemorial, were not tenanted, and had slopes exceeding 18%. The DAR Regional Director denied the petition, finding that the properties were not directly, actually, and exclusively used for pasture. It was established that petitioner had leased a portion to Monterey Farms Corporation and sold its entire herd of cattle to the lessee. Furthermore, one title was no longer in petitioner’s name. The Secretary of Agrarian Reform and the Office of the President subsequently affirmed the denial.
Petitioner elevated the case to the Court of Appeals, arguing that the ruling disregarded the Supreme Court precedent in Luz Farms v. Secretary of DAR, which exempted lands devoted to livestock from CARP, and that the lands had slopes of over 18%. The CA dismissed the petition. Petitioner thus filed this petition for review on certiorari before the Supreme Court.
ISSUE
Whether the Supreme Court should reverse the findings of the DAR, the Office of the President, and the Court of Appeals that petitioner’s landholdings are not exempt from CARP coverage.
RULING
The Supreme Court denied the petition and affirmed the assailed CA decision. The Court emphasized that factual findings of administrative agencies, like the DAR, when affirmed by the OP and the CA, are generally binding and conclusive if supported by substantial evidence. The Court found no compelling reason to deviate from this rule. The legal logic rests on the principle of finality of administrative factual determinations and the limited scope of a Rule 45 review, which precludes re-evaluation of evidence.
The Court held that petitioner failed to substantiate its claim for exemption under the Luz Farms doctrine. While the Constitution exempts lands actually, directly, and exclusively used for livestock, poultry, and swine-raising, the DAR correctly found that petitioner did not meet this standard. The sale of its entire herd and the leasing of the land demonstrated a cessation of direct and exclusive use for cattle ranching. The claim regarding the 18% slope was also a factual matter already passed upon by the lower bodies, and the Court found no error in their conclusion that the land was suitable for agriculture. Thus, the petition was denied for lack of merit.