MIDTERM, AND FINAL EXAMS.

40 % & 45% remaining 10 % is group grade critic ( major requirements and we should comply) Objective is to learn and the pointers will be given in advance Agrarian reform and other social legislations ( important during actual law practice) Midterm = agra law Final= sss and gsis legislation

There are no grounds to eject a tenant because the law assumes that all of them qualify as beneficiaries. Pd 27 the emancipation decree of marcos. ( covers rice and corn land)

6657 did not repeal pd 27.( lands of the public domain) Lands covered by the code( private agricultural lands) Tenanted areas landed estates old settlements Proposed settlement Composition of the code An agricultural leasehold system to replace all existing share tenency system in agriculture Why leasehold Protects tenurial and economic status Guarantees physical possession enjoyment and management Assures continuity of relations In case lessor sells or alienates the legal possession, transferee shall be subrogated to the rights and substituted to the obligations of lessor. o Even though the relationship is not annotated in the title. o To prove you may execute an affidavit when you assumes as farmer or when your parents assumed as farmers

Feel free to make a critic, once submitted it will also be submitted to the appropriate agencies. Once submitted it is an authority in itself to send it. Agrarian reform , sss, gsis

Every meeting
No recitation Discuss 3 absent there must be permission from dean largo to get back to the class

Read in advance whatever discussion for the day especially the cases in agrarian reform. Feel free to ask questions anytime. Outside of class, provided it is related to our subject. Passing is 75% per policy it can be lowered to 65%

June 30, 2012 Land ownership ( agricultural land) Meaning of social legislation Law seeks to promote the common good, generally by protecting and assisting the weaker members of the society.

If you are lawyering for the farmer this is a right even though there is sale of agri land the relationship subsists

Po vs dampal regarding legal redemption

Farm land in bukidnon was foreclosed by the bank for non-paymen tof loan and petitioner po is the highest bidder. After foreclosure they filed the case and challenged the legality of the mortgage. Meanwhile the tenant filed a complaint for legal redemption with darab Regional adjudicator disallowed redemption because of prescription and that the requirement of notice was complied because tenant was considered to have knowledge because of the civil case. Darab central office reversed on the lack of notice of sale to tenant and to dar. Since the tenant filed a civil case the tenent is considered to have a constructive notice of the foreclosure The requirement of section 12 is indispensable it must be reconed from the notice in writing and upon the registration of the sale

Meaning of social justice Social justice- is neither communism nor despotism nor atomisn nor anarchy, but the humanization of the laws and the equalization of social and economic forces by the state so that justice in its national and objectively secular conception may at least be approximated. Sss for private employees, masakit, mamatay mag retire. We need an equalization done through sss law Social justice. o Means the promotion of the welfare of all the people, the adaptation by government of measures calculated to insure economic stability of all the component.

JULY 7, 2012 Beneficiaries of the code ( ra 3844) Tenant farmers Agricultural wage-earners or farm workers Settlers including migrant workers Owner-cultivator of less than family-size farmers

Sec. 12 of Republic Act No. 3844 or the Agricultural Land Reform Code of 1963, as amended by Republic Act No. 6389, otherwise known as the Code of Agrarian Reforms of the Philippines, provides: Sec. 12. Lessees right of redemption. In case the landholding is sold to a third person

without the knowledge of the agricultural lessee, the latter shall have the right to redeem the same at a reasonable price and consideration: Provided, That where there are two or more agricultural lessees, each shall be entitled to said right of redemption only to the extent of the area actually cultivated by him. The right of redemption under this Section may be exercised within one hundred eighty days from notice in writing which shall be served by the vendee on all lessees affected and the Department of Agrarian Reform upon the registration of the sale, and shall have priority over any other right of legal redemption. The redemption price shall be the reasonable price of the land at the time of the sale. (emphasis supplied)
Ordinary redemption there is no need of notice.

To note, as early as November 10, 1986, Marciano executed an Affidavit[46] stating that Leon refused to receive the respective lease rentals consisting of 37 cavans for November 1985 and July 1986. For 1987, Marciano wrote Leon two letters[47] informing him of the availability of the lease rentals for April and October of the same year. Was not ejected

EXTINGUISHMENT OF RELATION VS DISPOSSESSION? EXTINGUISHMENT- NO COURT APPROVAL; VOLUNTARY ACT (ABANDONMENT OF LAND WITHOUT KNOWLEDGE OF LEASSOR Can this relation be terminated by death? No continue between lessor and members of the lessees immediate farm household to be chosen by lessor within 1 month from death; o Surviving spouse o Eldest direct descendant by consanguinity o Next eldest descendants in the order of their age.

GROUNDS TO DISPOSSESS A LESSEE? Failure to substantially comply with terms ans conditions unless by fortuitous event Planting of crops or use land for other purpose than that agreed Failure to adopt proven farm practices to conserve land Fault or negligence resulting in substantial damage Does not pay rental when due o Pinaka sikat nga ground to dispossess o As long as wa mu bayad it is sufficient ground already Employed a sublessee You cannot automatically eject a farmer. No there is ejectment case you will file it to the department of agrarian reform. The rate of the rental ( normally this is not cash)Shall not exceed 25% of the normal harvest of 3 consecutive years Rule 70 about ejectment, forcible entry and unlawful detainer. They do it on the contention that the occupant was tolerated to occupy the land.

LIABILITES OF THE LEASSOR IF HE EJECT TENENT WITHOUT AUTHORIZATION? Fine/ imprisonment damages suffered Attorneys fees Remuneration for the last income

Lease rental Shall not be more than the equivalent of 25 % of the average normal harvest during the 3 agricultural years immediately preceding the date of leasehold after deduction amount used for seeds cost of harvesting, threshing, loading hauling and processing Can they opt for higher? o No they cannot. But if they stipulate and the farmer does not complaint then it will govern but the farmer may question it anytime.

Sta ana vs carpo

A complaint was filed for ejectment due to non-payment of rentals PARAD ruled that there was default on payment of rentals; DARAB reversed that there was no such default; CA set aside the DARAB ruling and reinstated the PARAD Issue: Whether ther is failure to pay and whether ther is cause for ejectment.

PD 27 THE TENANTS EMANCIPATION DECREE BENEFICIARIES: Differences: PD 27- rice and corn land; tenant-farmer deemed owner of 5 hectares if not irrigated and 3 hectares if irrigated Ra 6657- all other agricultural land including lands of public domain; beneficiaries shall be awarded an area not exceeding 3 hectares.

Under Section 37 of Republic Act No. 3844,[40] as amended, coupled with the fact that the respondents are the complainants themselves, the burden of proof to show the existence of a lawful cause for the ejectment

of the petitioner as an agricultural lessee rests upon the respondents as agricultural lessors

Sigre vs ca
a petition for prohibition and mandamus docketed as CA-G.R. SP No. 28906, seeking to prohibit the Land Bank of the Philippines (LBP) from accepting the leasehold rentals from Ernesto Sigre (predecessor of petitioner Rolando Sigre), and for LBP to turn over to private respondent the rentals previously remitted to it by Sigre. It appears that Ernesto Sigre was private respondent's tenant in an

Respondents failed to discharge such burden. The agricultural tenant's failure to pay the lease rentals must be willful and deliberate in order to warrant his dispossession of the land that he tills.

irrigated rice land located in Barangay Naga, Pototan, Iloilo. He was previously paying private respondent a lease rental of sixteen (16) cavans per crop or thirty-two (32) cavans per agricultural year. In the agricultural year of 1991-1992, Sigre stopped paying his rentals to private respondent and instead, remitted it to the LBP pursuant to the Department of Agrarian Reform's Memorandum Circular No. 6, Series of 1978, which set the guidelines in the payment of lease rental/partial payment by farmer-beneficiaries under the land transfer program of P.D. No. 27. gave due course to the petition and declared Memorandum Circular No. 6 null and void.4 The LBP was directed to return to private respondent the lease rentals paid by Sigre, while Sigre was directed to pay the rentals directly to private respondent.5 In declaring Memorandum Circular No. 6 as null and void, the appellate court ruled that there is nothing in P.D. 27 which sanctions the contested provision of the circular;6 that said circular is in conflict with P.D. 816 which provides that payments of lease rentals shall be made to the landowner, and the latter, being a statute, must prevail over the circular;7 that P.D. 27 is unconstitutional in laying down the formula for determining the cost of the land as it sets limitations on the judicial prerogative of determining just compensation;8 and that it is no longer applicable, with the enactment of Republic Act No. 6657. 9 the Court need not belabor the fact that R.A. 6657 or the CARP Law operates distinctly from P.D. 27. R.A. 6657 covers all public and private agricultural land including other lands of the public domain suitable for agriculture as provided for in Proclamation No. 131 and Executive Order No. 229;36 while, P.D. 27 covers rice and corn lands. On this score, E.O. 229, which provides for the mechanism of the Comprehensive Agrarian Reform Program, specifically states: "(P)residential Decree No. 27, as amended, shall continue to operate with respect to rice and corn lands, covered thereunder. that R.A. 6657 did not repeal or supersede, in any way, P.D. 27. And whatever provisions of P.D. 27 that are not inconsistent with R.A. 6657 shall be suppletory to the latter,38 and all rights acquired by the tenantfarmer under P.D. 27 are retained even with the passage of R.A. 6657

Used among other in: Sec 6 retention limit- except as otherwise provided in this act, no person may own or retain directly.

JULY 21,2012 DEFINITIONS AGRARIAN DISPUTE SECTION 3(D) USED AMONG OTHERS, IN: Section 47. functions of BARC Section 53. certification of BARC Section 54. Certiorari- any decision order award or ruling of the Dar on any agrarian dispute or on any matter pertaining to the application

Any controversy relating to tenurial arrangements (leasehold, tenancy, stewardship) over land devoted to agriculture Any controversy relating to compensation of lands acquired under CARL and other terms and conditions

Essential requisites ( land owner) Parties tenants. And land owner o Landowner can be in the person of a lessee Subject matter is agricultural land o The fact that the land is agricultural does not make the dispute agrarian. It is only one of the requisites Consent of parties o It can be express or implied o Can be affidavit agreement any piece of paper to show consent of the parties o The burden on proof would normally lie on the tenant Purpose is agricultural production o The purpose can oalso be gleemed on the agreemtn on the part of the tenant to cultivate and the parties will produce. o It can be implied that the tenant will cultivate. The land owner shares and also the tenant Personal cultivation by tenant o This is the essence of tenancy someone os tilling the land of another o Express or implied. Sharing of harvest between parties o What if it is the child of the tenant who tills the land. And the children are the one who cultivates? o This is the option of the 4th requisite. o Even if 1-5 all of this are proven but you cannot prove sharing of harvest then there is no agrarian dispute. Then it does not lie on agrarian courts. Note: all requisites must concur, absence of one does not make one a tenant

can lands require under pd 27 be transferred by DAR to another qualified beneficiary? estolas vs mabalot
land may only be transferred wither by succession or to government

land bank vs heirs of cruz:

the determination of just compensation should be based on RA 6657 for lands covered under PD 27 PD 27 applies only suppletorily.

July 14, 2012

If you are not a tenant can you be ejected? Definition of agricultural land sec 3 c

Even if we are discussing 6657. Will ra 3844 govern in so far as that person is concerned.

zerna to return 1100 to Monsanto on the ground that Monsanto did not consent ot the harvest of the coconuts. Or kopra sale. Issue:

If the issue is not agrarian it is the civil courts that will have the jurisdiction

Who is entitles to 1100 proceeds of copra sale? This falls under darab. Sc. There is agrarian dispute: Subject of the dispute was the taking of the coconuts

Isidro vs ca Priv resp were overseers of the taking by virtue of the agreement. Private resp is owner of land Sister of priv resp allowed isidro the person who claimed to be tenant to occupy the subject portion subject to the condition to vacate upon demand. Failure to vacate, unlawful detainer was filed against isidro RTC dismissed because land is agricultural and so agrarian Sc: Jurisdiction over subject matter determined from allegations of complaint Court does not lose jurisdiction by defense of tenancy relationship and only after hearing that, if tenancy is shown, the court should dismiss for lack of jurisdiction Case involving agri land does not automatically make such case agrarian 6 requisites were not present No contract to cultivate Petitioner failed to substantiate claim that ha was paying rent for use of land Suplico vs ca Suplico is a lessee of a rice land Private respondent was allowed by suplico to till the land while suplico will provide the farm implements ans thereafter suplico was to receive cavans from the palay by way of rental Years later, suplico threatened to eject the priv resp from the property So private respondent files an action for damages against suplico in CAR Sc: The sc found that there are no reasons to disturb the findings. The priv resp is in actual possession of the land with family in a farmhouse just like what a farm. The private resp and the wife were plowing weeding, and harvesting cultivation Management was left entirely to private respondent who defrayed the cultivation expenses. Priv resp shared with suplico the harvest. Suplico is not mandated to pronounced that the 6 requisites are present. So if you are the side of the land owner you must raise it at the earliest time. Rtc ca and then the sc. Factual findings sa lower court pildin na daan Petitioner allowed resp to plant coconut. Receipts of the remittance were established. Petitioner is claiming that the amount of 1100 as balance from proceeds of copra sale Private respondents contended that theis 1100 is their compensation pursuant to tenurial Bejasa vs ca Candelaria owned 2 parcel of land, which she leased to malabanan. Malabanan hired the bijasas to plant the land, clear it to all the expenses shouldered by malabanan. Bejasas continued to stay Issue: whether there is tenancy relationship Sc: Theyer was no tenancy relationship between the parites. There was no proof that the malabanan ans the bejassas shared the harvest. The court noted about inconsistency. That the testimony of the bejasas was suspicious because they testified to deliver.

Monsanto vs zera The zernas were charged with qualified theft they were allegedely taking coconuts . they were acquitted buyt tupon acquittal the trial court required

August 4, 2012 RETENTION RIGHTS NCC: CONJUGAL total is 5 Capital paraphernal- not more than 5 each but not exceed 10

the option to choose whether to remain therein be a beneficiary in the same or or another agricultural land with similar or comparable features. In case the tenant chooses to

Family code ( aug 3 1988) per DAR admin order no 2 s 2003 o Capital paraphernal- not to exceed 5 provided with judicial separation o Absolute(presumed) total not exceed 5

remain in the retained area, he shall be considered a leaseholder and shall lose his right to be a beneficiary in another agricultural land, he loses his right as a leaseholder to the land retained by the landowner. The tenant must exercise this option
within a period of one (1) year from the time the landowner manifests his choice of the area for retention. In cases, the security of tenure of the farmers or farm workers on the land prior to the approval of this Act shall be respected. Upon the effectivity of this Act, any sale, disposition, lease, management contract or transfer of position of private lands executed by the original landowner in violation of this Act shall be null and void: Provided, however, That those executed prior to this Act shall be valid only when registered with the Register of Deeds within a period of three (3) months after the effectivity of this Act . Thereafter, all registers of Deeds shall inform the DAR within thirty (30) days of any transaction involving agricultural lands in excess of five (5) hectares.

Section 6 retention limits

SEC. 6. Retention Limits.- --Except as otherwise provided in this Act, no person may own or retain, directly, any public or private agricultural land, the size of which shall vary according to factors governing a viable family-sized farm, such as commodity produced, terrain, infrastructure, and soil fertility as determined by the Presidential Agrarian Reform Council (PARC) created hereunder, but in no case shall retention by the landowner exceed five (5) hectares. Three (3) hectares may be awarded to each child to the landowner, subject to the

following qualifications: (1) that he is at least fifteen (15) years of age; and (2) that he is actually tilling the land or directly managing the farm: Provided That landowners
whose lands have been covered by Presidential Decree No. 27 shall be allowed to keep the area originally retained by them thereunder ; Provided, further, That original homestead grantees or direct compulsory heirs who still own the original homestead at the time of the approval of this Act shall retain the same areas as long as they continue to cultivate said homestead.

The right to choose the area to be retained,

which shall be compact or contiguous, shall pertained, to the land owner ; provided, however, That in case the area selected for retention by the landowner ; is tenanted, the tenant shall have

In this case the law did not say that the 3 hectares of each child is a retention right. ( walay butang nga retention right the word used is awarded) It is the government who will award It will appear that the child will be beneficiary of the program the hierarchy the children of the land owner are given the priority. There is no requirement that the child has to be landless The law does not provide for a scenario in case where a 3 hectares awarded to the child in case there are tenants does the tenants have the right to choose to remain as tenants or become a beneficiary under the law.

The land holdings of land owners with a total area of 5 hectares and below shall not be convered.

Retention by land owners: 56 hectares Retention by each child of landowner is 3

Dar admin order #2 s 2003 Who may apply for retention Period to exercise right of retention Where to file Instance where owner is considered to have waived his right of retenetion Operating procedure

Is the right defeated by the issuance of clts eps or cloas? Daez vs ca

compulsory acquisition , a simple and absolute majority of the actual regular workers or tenants must consent to the exemption within one (1) year from the effectivity of this Act. When the workers or tenants do not agree to this exemption, the fishponds or prawn farms shall be distributed collectively to the worker-beneficiaries or tenants who shall from cooperative or association to manage the same. In cases where the fishponds or prawn farms have not been subjected to the Comprehensive Agrarian Reform Law, the consent of the farm workers shall no longer be necessary ; however, the provision of Section 32-A hereof on incentives shall apply. c) Lands actually, directly and exclusively used and found to be necessary for national defense, school sites and campuses, including experimental farm stations operated by public or private schools for educational purposes, seeds and seedlings research and pilot production center, church sites and convents appurtenant thereto, mosque sites and Islamic centers appurtenant thereto, communal burial grounds and cemeteries, penal colonies and penal farms actually worked by the inmates, government and private research and quarantine centers and all lands with eighteen percent (18%) slope and over, except those already developed, shall be exempt from the coverage of this Act. ( As amended by R.A 7881) Lands used actual directly exclusively used for parks, wildlife forest reserves reforestation fish sanctuariesd and breeding grounds watersheds and mangroves( exempt) Private lands ade used for prawn farms and fishponds( exempt) Lands ADE used and found to be necessary for national defense, school sites and campuses including experimental

Exception to the retention limitProvincial city and municipal government units who will aquire agricultural lands by expropriation or other modes of acquisition to be used for actual, direct and exclusive public purposes such as roads and bridges public markets schools sites resettlement sites local government facilities public parks and barangay plazas or squares, consistent with the approved local comprehensive

Section 10 exemptions and exclusions

SEC. 10. Exemptions and Exclusions.a) Lands actually, directly and exclusively used for parks, wildlife, forest reserves, reforestation, fish sunctuaries and breeding grounds, watersheds and mangroves shall be exempt from the coverage of this Act. b) Private lands actually, directly and exclusively used for prawn farms and fishponds shall be exempt from the coverage of this Act: Provided, That said prawn farms and fishponds have not been distributed and Certificate of Land Ownership Award (CLOA) issued to Agrarian Reform Program. In cases where the fishponds or prawn farms have been subjected to the Comprehensive Agrarian Reform Law, by voluntary offer to sell, or commercial farms deferment or notices of

farm stations, seeds and seedlings research, church sites and convents, mosque sites, communal burial grounds and cementaries, penal colonies and farms and all lands with 18% slope over (exempt)

Central Mindanao vs darab The subject lands are exempted because they are actually, directly and exclusively used and found necessary for school site ans campus including experimental farm stations for educational purposes ans establishing seed and seeding research While portion of cmu land was leased by t=phil packing corp ( now del monte) the agreemtn was prior to CARL and was directly connected to the purpose ans objectives of CMU as educational institution As to determination of when and what lands are found to be necessary for use of cmu schoolis in best position
Atlas fertilizer vs sec (acquaculture) Sanchez vs marin( fishpond) Republic vs ca(slope) Tax declaration classified subject land as agricultural Dar issued notice of coverage and owner applied for exemption Sc: it was confirmed that the land used map submitted by private respondents

SEC. 11. Commercial Farming Commercial farms which are private agricultural lands devoted to salt beds, fruit farms, orchards, vegetable and cut-flower farms, and cacao, coffee and rubber plantations, shall be subject to immediate compulsory acquisition and distribution after ten (10) years from the effectivity of this Act. In the case of new farms, the ten-year period shall begin from the first year of commercial production and operation, as determined by the DAR. During the ten-year period, the Government shall initiate steps necessary to acquire these lands, upon payment of just compensation for the land and the improvements thereon, preferably in favor of organized cooperatives or associations, which shall thereafter manage the said lands for the workers-beneficiaries. (As amended by R.A. 7881) Commercial farms- private agri lands devoted to saltbeds, fruit farms, orchards, vegetable and cut flower farms and cacao, coffee ans rubber plantations. They are subject to compulsory acquisition ans distribution after 10 years from effectivity Luz farms vs sec

Alternative methods available to commercial farms other than distribution of lands: 1. 2. 3. 4. Joint land venture Lease-back Growership arrangements Direct payment scheme

Sta rosa vs ca( non-agricultural land and slope) Issue: The entire property was part of a water shed area Sc: to resolve the issue as to the nature of the parcels

These are aside from usual VOS an compulsory coverage.

Joint venture The beneficiaries contribute use of lands( individually or in common) and the facilities and improvements if any

Commercial farm( section 11)

The investor furnished capital and technology for production, processing and marketing of agricultural goods Must be approved by dar Lease contract The beneficiaries bind themselves to give the investor the enjoyment or use of their land for a certain price and for a definite period Dar may consider this type Lease my not exceed 10 years subject to extentsion by mutual agreement The lease rental should not be less than the amortization to be paid by the workers to lbp which paid the land owner. Grownership

Non land transfer schemesSection 12 of ra 6657 SEC. 12. Determination of Lease Rentals .--In order to protect and improve the tenurial and economic status of the farmers in tenanted lands under the retention limit and lands not yet acquired under this Act, the DAR is mandated to determine and fix immediately the lease rentals thereof on accordance with Section 34 of R.A. No. 3844 as amended : Provided, That the DAR shall immediately and periodically review and adjust the rental structure for different crops, including rice and corn, of different regions in order to improve progressively the conditions of the farmer, tenant or lessee. Section 6 recognizes the right of farmer to elect either of the following: o As farmer-beneficiary o Leasehold in retention area

Workers farm the land and agree to pre sell their produce individually or collectively to any party including the former land owner SEC. 67. Free Registration of Patents and Titles.-- All registers of Deeds are hereby directed to Direct payment register, free from payment of all fees and to sel the land and or equipment The contract must be approved by dar and majority of workers Dar further requires that the cloa be issues collectively or under co ownership. of the CARP.

other charges, patents, titles and The land owner ans the workers can agree documents required for the implementation
* pursuant to dars mandate to protect the rights ans impove tenurial ans economic status of farmers in tenanted lands, dar issues a.o no 2-6 Leasehold is based on tenancy realtionshio (6 requisites: note: 6th req: there is consideration given to the lessor either in a form of share of the harvest or payment or fixed amount in money) Darab has jurisdiction to cancel leasehold contract o Because the leasehold contract contains rights and it is darab who exercises quasi judicial functions Consideration shouldnot be more than 25% of average normal harvest during 3 agri years A.o no 2-06 states, among others the rights ans bligations of lessor/lessee

Admin irder no 9 s 1998- allows commercial farms certain options subject to approval of the dar ans workers( aside from voluntary agreement) Chapter 3 Improvement of tenurial and labor relation Ways in distributing lands to qualified farmers? Compulsory acquisition ( section 16) Voluntary offer to sell/ voluntary land transfer ( section 20)

Capter 4 registration Section 14& 15

in the barangay where it shall be open to inspection by the public at all reasonable hours.

SEC. 14. Registration of Landowners .---Within one hundred eighty (180) days from the effectivity of this Act, natural or juridical, including government entities, that own or claim to to own agricultural lands, whether in their names or in the name of others, except those who have already registered pursuant to Executive Order No.229, who shall be entitled to such incentives as may be provided for by PARC, shall file a sworn statement in the proper assessors office in the form to prescribed by the DAR, stating the following information: (a) The description and area of the property; (b) The average gross income from the property for at least three (3) years (c) The names of the tenants and farm workers therein; (d) The crops planted in the property and the area covered by each crop as of June 1,1987 (e) The terms of mortgages, leases, and management contracts subsisting as of June 1, 1987 ; and (f) The latest declared market value of the land as determined by the city or provincial assessor. SEC. 15. Registration of Beneficiaries. ---The DAR in coordination with the Barangay Agrarian Reform committee (BARC) as organized in this Act, shall registered all agricultural lessees, tenants and farm workers who are qualified to be beneficiaries with the assistance of the BARC and the DAR shall provide the following data: a) Names and members of their immediate farm household ; b) Location and area of the land they work; c) Crops planted ; and d) Their share in the harvest or amount of rental paid or wages received. A copy of the registry or list of all potential CARP beneficiaries in the barangay shall be posted in the barangay hall, school or other public buildings

FORTICH VS CORONA INTERVENORS claimed that they are farmworkers ans so intervened in the case Sc: there is no rulking yet from dar whether intervenors are beneficiaries, so they have no standing yet to intervene in the case Dar safeguards the list of ARB thru ids

Concha vs rubi the controvery is who between petitioners are qualified to become beneficiaries. Sc: It was the decision of the maro not to include re3spondents as farmer beneficiaries. Kai gihatagan sila og form para ma facilitate wala sila mu pirma. According to the maro after the respondents build their houses in 1993 in the lots ans after the above mentioned sinumpaanf salayasay The decision must be accorded respect in the absence of the abuse of discretion.