G.R. No. L-28609 & L-28610. January 17, 1974.
ZOILA DE CHAVEZ, ET AL., petitioners, vs. ENRIQUE ZOBEL and COURT OF APPEALS, respondents.

FACTS

Private respondent Enrique Zobel, the registered owner of Hacienda Bigaa in Calatagan, Batangas, filed petitions to eject the petitioners, who were his tenants on portions of the hacienda. Zobel relied on Republic Act No. 1199 , which allowed ejectment if the landholding was suited for mechanization. The petitioners-tenants opposed the ejectment, contending that their small landholdings were not suitable for mechanization and alleging that Zobel’s true intent was to convert the land for pasture and sorghum cultivation. The Court of Agrarian Relations dismissed Zobel’s petitions, doubting the sincerity of the mechanization plan and noting its impracticability during the rainy season.
The Court of Appeals reversed the agrarian court’s decision and ordered the ejectment of the tenants. The tenants elevated the case to the Supreme Court via petitions for review. The parties had stipulated before the Court of Agrarian Relations the existence of the landlord-tenant relationship and the specific areas cultivated by each petitioner-tenant, which ranged from half a hectare to six hectares.

ISSUE

Whether the petitioners-tenants can be lawfully ejected from their landholdings in light of Presidential Decree No. 27, which decreed agrarian reform and tenant emancipation.

RULING

The Supreme Court reversed the decision of the Court of Appeals and ruled in favor of the petitioners-tenants, holding that ejectment was no longer permissible. The Court anchored its ruling on the fundamental policy of agrarian reform enshrined in the new Constitution and effectuated by Presidential Decree No. 27, issued in October 1972. The decree explicitly emancipated tenants from the bondage of the soil and transferred ownership of the land they tilled to them. The Court emphasized that this decree had become part of the law of the land under the 1973 Constitution, which mandated the State to implement an agrarian reform program aimed at tenant emancipation.
Given this overarching constitutional and statutory policy, the legal basis for ejectment under Republic Act No. 1199 , even on grounds of mechanization, could not be sustained. To allow ejectment would directly contravene the express mandate for emancipation and the transfer of ownership to the tillers. The Court underscored the historical gravity of the tenancy problem and the social justice imperative of eradicating feudalistic structures. Consequently, the ejectment of the petitioners was deemed legally untenable, as it would nullify the constitutional objective of agrarian reform and tenant ownership. The decision of the Court of Appeals was set aside.