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Diamond Farms vs Diamond Farm Workers Multi-Purpose Coop

July 18, 2012


J. Villarama
Carlos Pagdanganan
Social Justice and Human Rights – Agrarian Reform

Facts of the case

The Petitioner and CARP


Petitioner is a corporation engaged in the commercial farming of bananas. A portion of the land it owns was placed under
CARP (Comprehensive Agrarian Reform Program) coverage. Thus, its certificates of title over portions of the land under
CARP were cancelled, and new TCT’s were issued in the name of the Republic of the Philippines. Subsequently,
beneficiaries were identified, most of whom were members of respondent cooperative. Certificates of Land Ownership
Award (CLOA) were issued for them.

Petitioner’s Complaint
Petitioner filed a complaint for unlawful occupation against respondents, alleging that it was the lawful owner of two
parcels of land within the portions covered by the CLOA and that the said CLOAs had yet to attain finality owing to appeals
filed by petitioner. Thus, while the beneficiaries had yet to be designated with finality, respondents refused to do work for
petitioner, and forcibly entered the land subject to the dispute and occupied the same.

Respondents Counterclaim
Respondents argued that indeed, petitioner had the TCT’s of the parcel of land subject to the dispute, but these were put
under the name of the Republic upon subjecting it to CARP. Thus, despite the award of CLOAs to respondents, petitioner
continued to manage the land while paying wages them. Respondents thus demanded that their rights under the CLOAs be
established, and that the petitioner pay them their production share.

The Lower Courts’ Ruling


The CA affirmed the DAR Adjudication Board ordering the petitioner to turn over the possession of the land to the
respondents.

Issue:
WON respondents are guilty of unlawful occupation. NO.

Ratio:
Respondents are not guilty of unlawful occupation
The action taken by respondents to guard the land was reasonable and necessary to protect their legitimate possession
and prevent what petitioner attempted to do.
- Respondents were simply protecting their right, after the petitioner’s attempt to thwart the CARP’s
implementation. What the petitioner did was install workers which it conspired with on land already identified
as falling under CARP and having CARP-designated beneficiaries. This served as an attempted roadblock to
installing the legitimate beneficiaries on the land.

Petitioners already lost ownership over the land


Petitioner itself acknowledged that there was a deposit of the initial valuation of the land. It even manifested that the
Republic’s TCT’s were neither attacked nor assailed in this case. Thus, upon petitioner’s own reasoning, it already lost
possession and ownership over the land when the condition (payment of just compensation) was fulfilled, which was not
disputed in this case.

Petitioner must turn over possession to respondents


Under Section 4, Article XIII of the 1987 Constitution and Section 2 of the CARL, the agrarian reform program is founded
on the right of farmers and regular farm workers who are landless to own directly or collectively the lands they till. The
policy on agrarian reform is that control over the agricultural land must always be in the hands of the farmers.
- Hacienda Luisita, Incorporated, etc. v. Presidential Agrarian Reform Council, et al
The court ruled that the Constitution and the CARL intended the farmers, individually or collectively, to have
control over agricultural lands, otherwise all rhetoric about agrarian reform will be for naught.