Suffering of landowners due to land reform for the GREATER GOOD

The Supreme Court explained in the Hospicio case: It is axiomatic that where a general rule is established by a statute with exceptions, the Court will not curtail nor add to the latter by implication, and it is a rule that an express exception excludes all others. We cannot simply impute into a statute an exception which the Congress did not incorporate. Moreover, general welfare legislation such as land reform laws is to be construed in favor of the promotion of social justice to ensure the well-being and economic security of the people. Since a broad construction of the provision listing the properties exempted under the CARL would tend to denigrate the aims of agrarian reform, a strict application of these exceptions is in order.
Archbishop cannot claim exemption in behalf of the millions of Filipino faithful, as the lands are clearly not exempt under the law. He should not fear that his followers are simply being deprived of land, as under both PD 27 and RA 6657, he is entitled to just compensation, which he may then use for the benefit of his followers. His situation is no different from other landowners affected by agrarian reform; they are somewhat deprived of their land, but it is all for a greater good.

As Association of Small Landowners in the Philippines, Inc. v. Secretary of Agrarian Reform recognized the revolutionary character of the expropriation under the agrarian reform law, we follow such lofty ideal for the resolution of this case. This grand purpose under the CARL must not be hindered by the simple expedient of appending conditions to a donation of land, or by donating land to a church. This is not to cast aspersions on religious organizations, but it is not fitting for them to be used as vehicles for keeping land out of the hands of the landless. The law is indubitably in line with the charitable ideals of religious organizations to ensure that the land they own falls into the hands of able caretakers and owners. As a religious leader, Archbishop can take solace in the fact that his lands are going to be awarded to those who need and can utilize them to the fullest. (G.R. No. 139285; December 21, 2007)