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NATALIA REALTY v. DEPARTMENT OF AGRARIAN REFORM

This case has been cited 19 times or more.

	GR No. 163598 2015-08-12	AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. FIL-ESTATE INC. JARDELEZA, J.
Respondents moved tor reconsideration, which the succeeding Regional Adjudicator, Conchita Minas, granted via an order dated September 8, 1998.[13] Regional Adjudicator Minas held petitioners with their admission that the land is located within the area reserved as Townsite of Lungsod Silangan by virtue of Presidential Proclamation No. 1637. She also cited Natalia Realty Inc. v. DAR,[14] which has held that land located within the Lungsod Silangan Townsite has been converted to residential use. The land not being agricultural, Regional Adjudicator Minas held that the DARAB did not acquire jurisdiction over the subject matter of petitioners' complaint.
	GR No. 200454 2014-10-22	HOLY TRINITY REALTY v. VICTORIO DELA CRUZ BERSAMIN, J.
Verily, the basic condition for land to be placed under the coverage of Republic Act No. 6657 is that it must either be primarily devoted to or be suitable for agriculture.[50] Perforce, land that is not devoted to agricultural activity is outside the coverage of Republic Act No. 6657.[51] An agricultural land, according to Republic Act No. 6657, is one that is devoted to agricultural activity and not classified as mineral, forest, residential, commercial or industrial land.[52] Agricultural activity includes the "cultivation of the soil, planting of crops, growing of fruit trees, raising livestock, poultry or fish, including the harvesting of such farm products; and other farm activities and practices performed by a farmer in conjunction with such farming operations done by persons whether natural or juridical."[53]
	GR No. 200491 2014-06-09	KASAMAKA-CANLUBANG v. LAGUNA ESTATE DEVELOPMENT CORPORATION PERALTA, J.
In view of the foregoing, this Court had, in multiple occasions, ruled that lands already classified as commercial, industrial or residential before the effectivity of the CARL, or June 15, 1988, are outside the coverage thereof.[32] In Natalia Realty, Inc. v. Department of Agrarian Reform,[33] for instance, we held that the DAR committed grave abuse of discretion when it placed undeveloped portions of land intended for residential use under the ambit of the CARL. Similarly, in Pasong Bayabas Farmers Association, Inc. v. Court of Appeals,[34] we nullified the decision of the Department of Agrarian Reform Adjudication Board (DARAB) declaring the land in dispute as agricultural and, thus, within the coverage of the CARL, when the same had already been reclassified as residential by several government agencies prior to the effectivity of the law. We likewise held in Junio v. Garilao[35] that properties identified as zonal areas not for agricultural use prior on June 15, 1988 are exempted from CARL coverage, even without confirmation or clearance from the DAR.
	GR No. 161796 2012-02-08	LAND BANK OF PHILIPPINES v. ESTATE OF J. AMADO ARANETA VELASCO JR., J.
In the main, the CA predicated its reversal action on the interplay of the ensuing premises, juxtaposed with the pertinent pronouncements in the cited cases of Natalia Realty, Inc. v. DAR[24] and Paris v. Alfeche,[25] among other landmark agrarian cases, thus: (1) Agricultural lands found within the boundaries of declared townsite reservations are reclassified for residential use. They ceased to be agricultural lands upon approval of their inclusion in the reservation, as in the case of agricultural lands situated within the LS Townsite reservation upon its establishment pursuant to Proclamation 1637.
	GR No. 169331 2011-09-05	AGAPITO ROM v. ROXAS DEL CASTILLO, J.
Indeed, respondent had previously voluntarily offered to sell to the DAR Hacienda Caylaway, where the properties subject of this case are located. However, this offer to sell became irrelevant because respondent was later able to establish before the DAR that the subject 27 parcels of land were reclassified as non-agricultural (residential) by virtue of (Nasugbu) Municipal Zoning Ordinance No. 4 prior to the effectivity of the CARL on June 15, 1988. "In Natalia Realty, Inc. vs. Department of Agrarian Reform,[56] it was held that lands not devoted to agricultural activity are outside the coverage of CARL including lands previously converted to non-agricultural uses prior to the effectivity of CARL by government agencies other than the DAR."[57] This being the case, respondent is not bound by its previous voluntary offer to sell because the subject properties cannot be the subject of a VOS, they being clearly beyond the CARP's coverage.
	GR No. 131481 2011-03-16	BUKLOD NANG MAGBUBUKID SA LUPAING RAMOS v. E. M. RAMOS LEONARDO-DE CASTRO, J.
DAR further avers that the reliance by the Court of Appeals -on Natalia Realty, Inc. v. Department of Agrarian Reform[19] (Natalia Realty case) is misplaced because the lands involved therein were converted from agricultural to residential use by Presidential Proclamation No. 1637, issued pursuant to the authority delegated to the President under Section 71, et seq., of the Public Land Act.[20]
	GR No. 180471 2010-03-26	ALANGILAN REALTY v. OFFICE OF PRESIDENT NACHURA, J.
Petitioner moved for reconsideration of the Order, arguing that the Alangilan landholding was already reserved for residential use as early as October 6, 1982. Invoking this Court's ruling in Natalia Realty, Inc. v. Department of Agrarian Reform,[7] petitioner insisted that the subject landholding was outside the coverage of the CARP. Petitioner also submitted a Supplemental to Motion for Reconsideration,[8] arguing that the landholding had already been reclassified as reserved for residential and had been earmarked for residential use even before the effectivity of the CARL. Accordingly, its non-development into a subdivision did not remove the landholding's zoning classification as reserved for residential.
	GR No. 154094 2010-03-09	DEPARTMENT OF AGRARIAN REFORM v. PABLO BERENGUER BERSAMIN, J.
To the same effect was Natalia Realty Corporation v. DAR,[14] thus: We now determine whether such lands are covered by the CARL. Section 4 of R.A. 6657 provides that the CARL shall "cover, regardless of tenurial arrangement and commodity produced, all public and private agricultural lands." As to what constitutes "agricultural land," it is referred to as "land devoted to agricultural activity as defined in this Act and not classified as mineral, forest, residential, commercial or industrial land." The deliberations of the Constitutional Commission confirm this limitation. "Agricultural lands" are only those lands which are "arable and suitable agricultural lands" and "do not include commercial, industrial and residential lands.
	GR No. 149548 2009-12-04	ROXAS v. DAMBA-NFSW CARPIO MORALES, J.
To determine the chief intent of PP 1520, reference to the "whereas clauses" is in order. By and large, a reference to the congressional deliberation records would provide guidance in dissecting the intent of legislation. But since PP 1520 emanated from the legislative powers of then President Marcos during martial rule, reference to the whereas clauses cannot be dispensed with.[6]
	GR No. 166748 2009-04-24	LAUREANO V. HERMOSO v. CA NACHURA, J.
In Natalia Realty, Inc. v. Department of Agrarian Reform[30], the Court held that lands not devoted to agricultural activity and those that were previously converted to non-agricultural uses are outside the coverage of the CARL, viz.:We now determine whether such lands are covered by the CARL. Section 4 of R.A. 6657 provides that the CARL shall "cover, regardless of tenurial arrangement and commodity produced, all public and private agricultural lands." As to what constitutes "agricultural land," it is referred to as "land devoted to agricultural activity as defined in this Act and not classified as mineral, forest, residential, commercial or industrial land." The deliberations of the Constitutional Commission confirm this limitation. "Agricultural lands" are only those lands which are "arable and suitable agricultural lands" and "do not include commercial, industrial and residential lands."
	GR No. 168394 2008-10-06	AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. LORETO G. NICOLAS REYES, R.T., J.
In ruling against petitioners and in favor of respondents, the CA applied Department of Justice (DOJ) Opinion No. 44 and this Court's ruling in Natalia Realty, Inc. v. Department of Agrarian Reform.[21] In both, the correct meaning and appreciation of what an agricultural land is were clarified. Natalia also laid the doctrine that once land has been classified as non-agricultural, it becomes outside the coverage of CARL.[22]
	GR NO. 169277 2007-02-09	DEPARTMENT OF AGRARIAN REFORM v. VICENTE K. UY CALLEJO, SR., J.
This Court's ruling in the Luz Farms case and Natalia Realty, Inc. v. DAR[58] was emphatic on the exemption from CARP of land devoted to residential, commercial and industrial purposes without any other qualifications. Moreover, after the passage of the 1988 CARL, Congress enacted R.A. No. 7881, amending certain provisions of the CARL. Specifically, the new law changed the definition of the terms "agricultural activity" and "commercial farming" by dropping from its coverage lands that are devoted to commercial livestock, poultry and swine-raising. With this significant modification, Congress clearly sought to align the provisions of our agrarian laws with the intent of the 1987 Constitutional Commission to exclude livestock farms from the coverage of agrarian reform.[59]
	GR NO. 156965 2006-10-12	FROILAN DE GUZMAN v. CA TINGA, J.
Under Section 3(c) of Republic Act (R.A.) No. 6657, otherwise known as the Comprehensive Agrarian Reform Law (CARL), an agricultural land refers to land devoted to agricultural activity as defined therein and not classified as mineral, forest, residential, commercial or industrial land. The deliberations of the Constitutional Commission confirm this limitation. "Agricultural lands" are only those lands which are "arable and suitable agricultural lands" and "do not include commercial, industrial and residential lands."[10]
	GR NO. 156965 2006-10-12	FROILAN DE GUZMAN v. CA TINGA, J.
In Natalia Realty, Inc. vs. Department of Agrarian Reform,[11] it was held that lands not devoted to agricultural activity are outside the coverage of CARL including lands previously converted to non-agricultural uses prior to the effectivity of CARL by government agencies other than the DAR. This rule has been reiterated in a number of subsequent cases. Despite claims that the areas have been devoted for agricultural production, the Court has upheld the "non-agricultural" classification made by the NHA over housing and resettlements projects,[12] zoning ordinances passed by local government units classifying residential areas,[13] and certifications over watershed areas issued by the Department of Environment and Natural Resources (DENR).[14]
	GR NO. 132073 2006-09-27	REMMAN ENTERPRISES v. CA CHICO-NAZARIO, J.
In Natalia Realty, Inc. v. Department of Agriculture,[18] this Court resolved the issue of whether lands already classified for residential, commercial or industrial use, as approved by the Housing and Land Use Regulatory Board (HLURB) and its precursor agencies, i.e., National Housing Authority and Human Settlements Regulatory Commission, prior to 15 June 1988, are covered by Republic Act No. 6657, otherwise known as the Comprehensive Agrarian Reform Law of 1988. We answered in the negative, thus:We now determine whether such lands are covered by the CARL. Section 4 of R.A. 6657 provides that the CARL shall "cover, regardless of tenurial arrangement and commodity produced, all public and private agricultural lands." As to what constitutes "agricultural land," it is referred to as "land devoted to agricultural activity as defined in this Act and not classified as mineral, forest, residential, commercial or industrial land." The deliberations of the Constitutional Commission confirm this limitation. "Agricultural lands" are only those lands which are "arable and suitable agricultural lands" and "do not include commercial, industrial and residential land."
	GR NO. 112526 2005-03-16	STA. ROSA REALTY DEVELOPMENT CORPORATION v. JUAN B. AMANTE AUSTRIA-MARTINEZ, J.
SRRDC cites the case of Natalia Realty, Inc. vs. DAR,[55] wherein it was ruled that lands not devoted to agricultural activity and not classified as mineral or forest by the DENR and its predecessor agencies, and not classified in town plans and zoning ordinances as approved by the HLURB and its preceding competent authorities prior to the enactment of R.A. No. 6657 on June 15, 1988, are outside the coverage of the CARP. Said ruling, however, finds no application in the present case. As previously stated, Municipal Ordinance No. 110-54 of the Municipality of Cabuyao did not provide for any retroactive application nor did it convert existing agricultural lands into residential, commercial, industrial, or institutional. Consequently, the subject property remains agricultural in nature and therefore within the coverage of the CARP.
	GR No. 149422 2003-04-10	DEPARTMENT OF AGRARIAN REFORM v. APEX INVESTMENT SANDOVAL-GUTIERREZ, J.
In Natalia Realty vs. Department of Agrarian Reform,[6] we held that the aggrieved landowners were not supposed to wait until the DAR acted on their letter-protests (after it had sat on them for almost a year) before resorting to judicial process. Given the official indifference which, under the circumstances could have continued forever, the landowners had to act to assert and protect their interests. Thus, their petition for certiorari was allowed even though the DAR had not yet resolved their protests. In the same vein, respondent here could not be expected to wait for petitioner DAR to resolve its protest before seeking judicial intervention. Obviously, petitioner might continue to alienate respondent's lots during the pendency of its protest. Hence, the Court of Appeals did not err in concluding that on the basis of the circumstances of this case, respondent need not exhaust all administrative remedies before filing its petition for certiorari and prohibition.
	GR Nos. 148404-05 2002-04-11	NELITA M. BACALING v. FELOMINO MUYA DE LEON, JR., J.
With respect to the third issue, we find that the one hundred ten (110) sub-lots are indeed residential. In Tiongson v. Court of Appeals[45] we held that if the lot in question is not an agricultural land then the rules on agrarian reform do not apply since the "key factor in ascertaining whether there is a landowner-tenant relationship xxx is the nature of the disputed property."[46] We reiterated this rule in Natalia Realty, Inc. v. Department of Agrarian Reform[47] where we excluded lands not devoted to agricultural activity, i.e., lands previously converted to non-agricultural or residential uses prior to the effectivity of the 1988 agrarian reform law (R.A. No. 6657) by agencies other than the DAR, from the coverage of agrarian reform. The statement of the rule is buttressed by P.D. No. 27 which by its terms applies only to "tenant-farmers of private agricultural lands primarily devoted to rice and corn under a system of shared-crop or lease tenancy, whether classified as landed estate or not."[48]