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The Court of Appeals via its 26 March 1997 decision ruled in favor of EMRASON and against
BUKLOD, stating that the land was already converted or classified as residential by the
Municipality of Dasmarias prior to Comprehensive Agrarian Reform Laws effectivity in 1988.
Issues:
1. Whether the Court of Appeals was right in ruling that the land owned by EMRASON, Inc
was not covered by agrarian reform since it was classified as non-agricultural/residential
lands by Municipal Ordinance 29-A?
Legal Provisions cited:
Municipal Ordinance 29-A made by the Municipality of Dasmarinas which says, Resolved, as
it is hereby resolved, to approve the application for subdivision containing an area of Three
Hundred Seventy-Two (372) Hectares situated in Barrios Bocal and Langkaan, named as
Traveller's Life Homes. Resolved that the Municipal Ordinance regarding subdivision
regulations existing in this municipality shall be strictly followed by the subdivision.
Section 3 of the Local Autonomy Act (R.A. No. 2264), which empowers a Municipal Council to
adopt zoning and subdivision ordinances or regulations for the municipality where it belongs.
Section 4 of R.A. 6657 or Comprehensive Agrarian Reform Law (CARL) of 1988 which says
that agrarian reform shall "cover, regardless of tenurial arrangement and commodity produced,
all public and private agricultural lands.
Held/Ruling: The Supreme Court ruled in favor of EMRASON, Inc. It stated that the lands
involved in the present case are not subject to agrarian reform since it was classified as
residential land by Municipal Ordinance 29-A of Municipality of Dasmarias prior to the
effectivity of the Comprehensive Agrarian Reform Law. It also reiterated the ruling in Natalia vs.
Department of Agrarian Reform that since a special law classified the land for residential,
commercial, or industrial use, that land or property cannot be anymore subject to agrarian
reform. The Court also used sec. 3 of RA 2264 or Local Autonomy Act to validate EMRASONs
application via Ordinance 29-A made by the Municipality of Dasmarias, Cavite.