G.R. No. L-26551. February 27, 1976.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellant, vs. WENCESLAO ALMUETE, FERNANDO FRONDA, FAUSTO DURION and CIPRIANO FRONDA, defendants-appellees.

FACTS

The accused, tenants of landowner Margarita Fernando, were charged with violating Section 39 of the Agricultural Tenancy Law ( Republic Act No. 1199 ). The information alleged that in December 1963, in Muñoz, Nueva Ecija, they pre-threshed a portion of their palay harvest without notice to or consent of the landholder, to her damage. Upon arraignment, they pleaded not guilty and later filed a motion to quash the information, arguing it failed to allege sufficient facts, that no law punished the act, and that the court lacked jurisdiction.
The trial court granted the motion and dismissed the information. It held the information was deficient for not describing the circumstances under which the palay was found in the tenants’ possession, not specifying the agreed threshing date, and not alleging that the palay exceeded ten percent of their net share. The prosecution appealed, with the Solicitor General contending the information sufficiently alleged all elements of the offense under Section 39, in relation to the penal provision in Section 57 of the same law.

ISSUE

Whether the accused may be validly prosecuted under Section 39 of the Agricultural Tenancy Law for the act of pre-threshing without notice committed in December 1963.

RULING

No. The Supreme Court affirmed the order of dismissal, ruling that Section 39 of the Agricultural Tenancy Law had been impliedly repealed. The act complained of occurred in December 1963, after the enactment of the Agricultural Land Reform Code ( Republic Act No. 3844 ) in August 1963. This Code, as subsequently amended and implemented by related decrees, superseded the Agricultural Tenancy Law and instituted the leasehold system while abolishing agricultural share tenancy.
The legal logic is grounded on the principle cessante ratione legis, cessat ipsa lex (the reason for the law ceasing, the law itself also ceases). The prohibition against pre-threshing in Section 39 was premised on the share tenancy system, aiming to prevent fraud in harvest division. With the abolition of share tenancy and its conversion to leasehold, where the tenant pays a fixed rental, the rationale for penalizing pre-threshing ceased to exist. The Agricultural Land Reform Code, a subsequent statute revising the entire subject matter, operated as a repeal of the inconsistent provisions of the old law, including Section 39. The Court, citing People vs. Adillo, emphasized that the new code did not reenact Section 39, indicating a deliberate legislative design to discard it. Consequently, the act charged had ceased to be a punishable offense under the subsequent agrarian reform law, depriving the court of jurisdiction to prosecute the accused under the repealed provision.