G.R. No. L-34584 November 29, 1984
Patricio Diga, petitioner, vs. Francisco V. Adriano and the Honorable Court of Appeals, respondents.

FACTS

Private respondent Francisco V. Adriano, the landowner, filed an ejectment case against his agricultural lessee, petitioner Patricio Diga, before the Court of Agrarian Relations (CAR). The ground for ejectment was the landowner’s desire for personal cultivation under Section 36(1) of Republic Act No. 3844 (Agricultural Land Reform Code). After trial, the CAR rendered judgment in favor of Adriano, authorizing Diga’s ejectment from the two-hectare landholding, subject to the condition that the owner must cultivate it for at least three years.
Petitioner Diga appealed to the Court of Appeals, which affirmed the CAR decision in its entirety. While his motion for reconsideration was pending before the appellate court, Republic Act No. 6389 (Code of Agrarian Reforms) took effect. This new law amended RA 3844 and removed “personal cultivation” as a valid ground for ejecting an agricultural lessee. Diga thus argued in his motion that the appellate court’s affirmance of his ejectment was now without legal basis.

ISSUE

Whether Section 7 of Republic Act No. 6389, which abolished personal cultivation as a ground for ejectment, should be given retroactive effect to apply to a case pending appeal at the time of the law’s enactment.

RULING

The Supreme Court ruled that RA 6389 cannot be applied retroactively and affirmed the decision ordering Diga’s ejectment. The Court held that statutes are generally prospective in application unless the legislature expressly provides for retroactivity, which RA 6389 does not. Applying the new law retroactively to this case would deprive the landowner of a vested right to eject the tenant, a right he had already asserted and obtained a favorable judgment for before the law was passed.
The Court emphasized that agrarian laws must be interpreted liberally to achieve their social objectives, but this liberality must extend to small landowners as well. The landholding in question was only two hectares, and the landowner’s motive for personal cultivation—to support his family of eight—was found to be sincere. Preventing a small landowner from working his own land would contravene the agrarian reform goal of creating self-reliant citizens and could result in an unjust sharing of poverty. The removal of personal cultivation as a ground was not intended to invalidate ejectment proceedings already initiated and adjudicated under the prior law.