PHILIPPINE SUPREME COURT JURISPRUDENCE

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EN BANC

G.R. Nos. L-20275-79     May 31, 1965

VIRGINIA B. UICHANCO, EDUARDO LIM and MERCEDES B. UICHANCO Petitioners, vs. FIDEL GUTIERREZ, MARCOS DE LA PE�A, GERARDO PECHO, REYNALDO MERCADO and FLAVIANO EVANGELISTA, Respondents.

BENGZON, C.J.: chanrobles virtual law library

Brought up on appeal from the Court of Agrarian Relations of the Fifth Regional District, Sta. Cruz, Laguna, these five cases involve one single issue: whether or not section 14 of Republic Act No. 1199, as amended, is constitutional.chanroblesvirtualawlibrary chanrobles virtual law library

Said section reads as follows:

The tenant shall have the right to change the tenancy contract from one of share tenancy to leasehold tenancy and vice versa and from one crop sharing tenancy. If the share tenancy contract is in writing and duly registered, the right to change from one crop sharing arrangement to another or from one tenancy system to another may be exercised at least one month before the beginning of the next agricultural year after the expiration of the period of the contract. In the absence of any registered written contract, the right may be exercised at least one month before the agricultural year when the change shall be effected." (as amended by Republic Act No. 2263)

According to the record: chanrobles virtual law library

The herein five respondents were, in the year 1960 - and before - share tenants of the herein petitioners, who own small rice farms in Calamba, Laguna. Pursuant to their verbal tenancy agreement, they shouldered the expenses of production and divided the harvest on a fifty-fifty basis. However, in the year 1960, the tenants demanded the conversion of their relationship from "share tenancy to "leasehold tenancy." They invoked the right granted by section 14 abovequoted. The landowners opposed, so these five litigations ensued.chanroblesvirtualawlibrary chanrobles virtual law library

The Court of Agrarian Relations, following the provisions of the law, upheld the tenants' demand and rendered judgment accordingly.chanroblesvirtualawlibrary chanrobles virtual law library

In due time, the landowners appealed to this Court, tendering the single issue of the validity of the statute hereinbefore copied. That law, they claimed, was unconstitutional because:

1. it interferes with the freedom of contract, and impairs contractual rights; chanrobles virtual law library

2. it deprives the landowner of his property in giving the tenant the right to impose a new legal relationship without his consent.

Their appeal was filed in September 1962; at that time, the question had not been resolved; in fact, a suit on the same issue pended before this Court (Juliano v. Court of Appeals, G.R. No. L-17627).chanroblesvirtualawlibrary chanrobles virtual law library

However, on May 29, 1964, in L-19555¹ this Court rendered judgment upholding the Constitutional validity of the statute. And we reiterated the same view in L-19750, July 17, 1964.² chanrobles virtual law library

It is unnecessary at this time to add to the reasons already explained in said two decisions. But referring to the circumstances in these litigations we note that apparently the parties herein entered the verbal tenancy relationship in 1956, at the earliest, because the first harvests mentioned in the decision were those of October 1957. Such being the case, it may be said that as the law then existing (Sec. 14) gave the tenant the right to demand a leasehold arrangement in exchange for the share tenancy, that right should be deemed included in their contract of tenancy; and the landlord may not now be heard to complain about interference with it or impairment thereof by the law.³ chanrobles virtual law library

It may be noted, in passing, that the Land Reform Code, approved August 8, 1963, Republic Act 3844, abolished agricultural share tenancy (sec. 4) even as it reaffirmed the privilege of tenants⁴ to elect the leasehold system.chanroblesvirtualawlibrary chanrobles virtual law library

On the basis of a leasehold system which it deemed established upon the tenants' demand, the Agrarian Court made a computation of rental to be paid and of distribution of the harvest - with facts and f figures. We have been shown no error in its computation. The sole issue presented for our determination is the validity of the law, which appellants assail on constitutional grounds. On that issue, consistently with our previous rulings, we have to uphold the legislative enactment.chanroblesvirtualawlibrary chanrobles virtual law library

WHEREFORE, the appealed decision of the Agrarian Court must be, and is hereby, affirmed. Without costs.