Sta. Rosa Realty Development Corp vs.

Court of Appeals

Facts:

The case is a petition regarding Department of Agrarian Reform Adjudication Boards (DARAB) order of
compulsory acquisition of petitioners property under the Comprehensive Agrarian Reform Program
(CARP). Sta. Rosa was the registered owner of two parcels of land in Cabuyao Laguna. According to
them, these lands are watersheds which provide clean and potable (drinkable) water to the Canlubang
community and that 90 light industries are located in that area. They were alleging respondents usurped
its rights over their property thereby destroying the ecosystem. Since the said land provides water to the
residents, respondents sought an easement of a right of a way to and from Barangay Castile, to which, by
counterclaim, Sta. Rosa sought ejectment against respondents. Respondents went to the DAR and filed a
case for compulsory acquisition of the Sta. Rosa Property under the Comprehensive Agrarian Reform
Program. Compulsory acquisition is the power of the government to acquire private rights in land without
the willing consent of its owner or occupant in order to benefit the society. The said land was inspected by
the Municipal and Agrarian Reform Officer, and upon consensus of the authorities concerned, they
decided that the said land must be placed under compulsory acquisition. Petitioners filed an objection on
the ground that: The area is not appropriate for agricultural purposes. The area was rugged in terrain with
slopes 18% and above. (which falls under the exception in compulsory acquisition of CARP) The
occupants of the land were illegal settlers or (squatters) who by no means are entitled to the land as
beneficiaries. Another issue raised by the petitioners was that the DAR failed to follow the due process
because instead of paying just compensation, a trust account was made in favour of the petitioners.

Issues:

1. Whether these parcels of land fall within the coverage of the Compulsory Acquisition Program of the
CARP?

2. Whether the petition of land conversion of the parcels of land may be granted?

Court Ruling:

1. Art. 67 of the Water Code: Any watershed or any area of land adjacent to any surface water or
overlying any ground water may be declared by DENR as a protected area. In this case, the DENR did
not declare the land as a protected area, In the past the municipality issued a resolution that the said land
is an agricultural land.

2. Although evidence of petitioners is strong, the Supreme Court opines that the area must be maintained
for watershed purposes for ecological and environmental considerations despite the 88 families who are
beneficiaries of the CARP. It is important that a larger view of the situation be taken because of the
thousands of residents downstream if the watershed will not be protected and maintained for its natural
purpose.

3. Despite Supreme Courts strong opinion of protection of watersheds as an intergenerational

responsibility, they however ordered to DARAB to conduct a re-evaluation of the case since the said land
falls under exception.