Central Mindanao University vs DARAB [Case Digest]

Central Mindanao University vs DARAB

G.R. No. 100091

G-one T. Paisones

 

Facts:

Complaint filed by complainants calling themselves as the Bukidnon Free Farmers and Agricultural Laborers Organization (BUFFALO) against the CMU, before the Department of Agrarian Reform for Declaration of Status as Tenants, under the CARP.

The petitioner, the CMU, is an agricultural educational institution owned and run by the state located in the town of Musuan, Bukidnon province.

From its beginning, the school was the answer to the crying need for training people in order to develop the agricultural potential of the island of Mindanao. Those who planned and established the school had a vision as to the future development of that part of the Philippines. On January 16, 1958 the President of the Republic of the Philippines, the late Carlos P. Garcia, "upon the recommendation of the Secretary of Agriculture and Natural Resources, and pursuant to the provisions of Section 53, of Commonwealth Act No. 141, as amended", issued Proclamation No. 476, withdrawing from sale or settlement and reserving for the Mindanao Agricultural College, a site which would be the future campus of what is now the CMU.

Under the terms of a contract called Addendum To Existing Memorandum of Agreement Concerning Participation To The CMU-Income Enhancement Program a former employee would be grouped with an existing selda of his choice and provided one (1) hectare for a lowland rice project for one (1) calendar year. He would pay the land rental participant's fee of P1,000.00 per hectare but on a charge-to-crop basis. He would also be subject to the same prohibitions as those imposed on the CMU employees. It was also expressly provided that no tenant - landlord relationship would exist as a result of the Agreement.

The non-renewal of the contracts, the discontinuance of the rice, corn and sugar cane project, the loss of jobs due to termination or separation from the service and the alleged harassment by school authorities, all contributed to, and precipitated the filing of, the complaint.

On the basis of the above facts, the DARAB found that the private respondents were not tenants and cannot therefore be beneficiaries under the CARP. At the same time, the DARAB ordered the segregation of 400 hectares of suitable, compact and contiguous portions of the CMU land and their inclusion in the CARP for distribution to qualified beneficiaries.

 

Issue:

Whether or not DARAB is correct in ordering the segregation of 400 hectares of suitable, compact and contiguous portions of the CMU land.

 

Held:

No.

 

Ratio:

The construction given by the DARAB to Section 10 restricts the land area of the CMU to its present needs or to a land area presently, actively exploited and utilized by the university in carrying out its present educational program with its present student population and academic facility -- overlooking the very significant factor of growth of the university in the years to come. By the nature of the CMU, which is a school established to promote agriculture and industry, the need for a vast tract of agricultural land for future programs of expansion is obvious.