Tax Declaration v. On-Site Inspection

The Department of Agrarian Reform argued that the tax declarations covering the lands characterized them as agricultural lands and, thus, detracted from the claim that they were used for livestock purposes.

It has been held that "there is no law or jurisprudence that holds that the land classification embodied in the tax declarations is conclusive and final nor would proscribed any further inquiry." Tax declarations are not the sole basis of the classification of the land; they are not conclusive so as to prevent their exclusion from the Comprehensive Agrarian Reform Program coverage as lands devoted to livestock-raising. The Municipal Agrarian Reform Officer's on site inspection and actual investigation showing that the lands were being used for livestock-grazing are more convincing in the determination of the nature of the lands.

Just because the on site investigation was belatedly conducted three or four years after the effectivity of the law (CARL) does not perforce make it unworthy of belief or unfit to be offered as substantial evidence. Absent any clear showing of grave abuse of discretion or bias, the findings of the Municipal Agrarian Reform Office, are to be accorded great probative value, owing to the presumption of regularity in the performance of his official duties  (RP rep by DAR v. Salvador Lopez Agri Bus., Corp; Salvador Lopez Agri Bus., Corp v. DAR, G.R. No. 178895 & G.R. No. 179071. January 10, 2011).