GR L 1505; (May, 1948) (Digest)
G.R. No. L-1505; May 12, 1948
Valentin Camacho, Bonifacio Macaranas, et al., petitioners, vs. The Court of Industrial Relations, Angeles Canson and Teresa Melgar de Carretero, respondents.
FACTS
Petitioners, tenants, and respondents, landowners, were involved in a dispute over the sharing of the palay harvest from haciendas in Sta. Barbara, Pangasinan, for the agricultural year 1946-1947. The Tenancy Law Enforcement Division of the Department of Justice had ordered a 70-30 division in favor of the tenants after deducting harvesting and threshing expenses, applying Section 3 of Republic Act No. 34 (which amended the Rice Share Tenancy Act, Act No. 4054 ). The Court of Industrial Relations reversed this, ruling that an oral contract embodying old customs governed the sharing, based on Section 8 of Act No. 4054 and Commonwealth Act No. 53 , and that applying Republic Act No. 34 would unconstitutionally impair contractual obligations.
ISSUE
Whether the Court of Industrial Relations erred in applying an oral tenancy contract and in holding that Republic Act No. 34 was not effective in Pangasinan for the 1946-1947 agricultural year.
RULING
Yes, the decision of the Court of Industrial Relations is reversed.
(1) Act No. 4054 (the Rice Share Tenancy Act) had been in effect in Pangasinan since January 1937. Its Section 4 required tenancy contracts to be in writing to be valid. Commonwealth Act No. 53 , which allowed oral tenancy contracts to be proved by tenant testimony, is a general law that does not repeal the special provisions of Act No. 4054 . Therefore, no valid oral tenancy contract could exist in Pangasinan after 1937. The sharing must be governed by the written requirements and sharing basis of Act No. 4054 and its amendments.
(2) Republic Act No. 34 , which amended the sharing provisions of Act No. 4054 , took effect upon its approval on September 30, 1946. Presidential Proclamation No. 14 (November 1946), which declared Act No. 4054 as amended in full force nationwide, applied only to areas where the Act was not already in force. Since Act No. 4054 was already effective in Pangasinan since 1937, Republic Act No. 34 became effective there immediately on September 30, 1946, and applied to the 1946-1947 agricultural year. The constitutional prohibition against impairing contracts does not apply because no valid oral contract existed. The promotion of social justice under the Constitution empowers Congress to regulate landlord-tenant relations, and such laws are read into and form part of contracts.
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