GR 29489; (December, 1968) (Digest)
G.R. No. L-29489 December 24, 1968
ANGEL M. TINIO, plaintiff-appellant, vs. FLORENCIO ANTONIO, ET AL., defendants-appellees.
FACTS
Plaintiff-appellant Angel M. Tinio, a landholder, sought to dispossess his tenants, defendants-appellees Florencio Antonio et al., on the ground of his intention to mechanize his farm. Prior to the effectivity of the Agricultural Land Reform Code on August 8, 1963, Tinio obtained the required certifications from the Agricultural Tenancy Commission (March 22, 1963) and the National Resettlement and Rehabilitation Administration (May 30, 1963) under Section 50 of the Agricultural Tenancy Act. The brief did not clearly show the date or written form of the notice served on the tenants. Tinio filed his complaint in the Court of Agrarian Relations on July 11, 1965. The defendants moved to dismiss based on Section 168 of the Agricultural Land Reform Code, which preserved the right to dispossess under the previous statute only if proper notices were served on the tenants at least two months prior to the Code’s approval (i.e., by June 8, 1963). The Court of Agrarian Relations dismissed the cases for lack of jurisdiction. The appeals, certified by the Court of Appeals, raised the constitutionality of Section 168.
ISSUE
Whether Section 168 of the Agricultural Land Reform Code is unconstitutional for its retroactive application, thereby depriving the landholder of a vested right in violation of due process.
RULING
No, Section 168 is not unconstitutional. The Court upheld the dismissal by the Court of Agrarian Relations. First, Section 168 is essentially procedural in character. The retroactive application of procedural laws does not violate any right of a party and is not constitutionally objectionable. Second, even assuming the right was substantive, the retroactive application here does not constitute a denial of due process. Due process is freedom from arbitrariness and unfairness. Section 168, on its face, shows legislative concern for pending mechanization actions and is neither unreasonable nor oppressive. The landholder was aware of the ongoing legislative debates on comprehensive land reform. The Court found the attack on the validity of Section 168 to be flimsy and insubstantial.