G.R. No. L-11968, December 29, 1959
Doroteo Onofre, et al., petitioners, vs. Hon. Pastor P. Reyes, et al., respondents.

FACTS

On August 4, 1956, Doroteo Onofre and eight other tenants of landholder Ramon Cabral petitioned the Court of Agrarian Relations to compel the landholder to agree to a change in their crop-sharing arrangement from 45-55 (in favor of the landholder) to 30-70 (in favor of the tenants). They based their demand on Section 14 of Republic Act No. 1199 (the Agricultural Tenancy Act of 1954). The landholder opposed the petition and moved to dismiss it, arguing that under the last part of Section 14, the tenants could only go to court one agricultural year after serving notice of their intention to change upon the landholder, and that the tenants had not given such notice. The tenants initially asserted they had given notice but later argued that such notice was unnecessary because they were not asking for a change to the leasehold system but merely a change from one crop-sharing arrangement to another under the share tenancy system. The Court of Agrarian Relations ruled in favor of the landholder, interpreting the phrase “in both cases” in Section 14 to mean that the one-year notice requirement applied to both a change to leasehold and a change in crop-sharing arrangement. It therefore dismissed the petition for lack of a condition precedent. The tenants appealed to the Supreme Court.

ISSUE

Whether the one-year notice requirement under the last sentence of Section 14 of Republic Act No. 1199 applies to a tenant’s petition to change from one crop-sharing arrangement to another under the share tenancy system.

RULING

No. The Supreme Court reversed the decision of the Court of Agrarian Relations. It held that the one-year notice requirement under the last part of Section 14 (“In both cases the change to the leasehold system shall be effective one agricultural year after the tenant has served notice of his intention to change upon the landholder”) applies only to instances where the tenant seeks to change from share tenancy to the leasehold system. The phrase “in both cases” refers to the two preceding sentences in the section: (1) where the share tenancy contract is in writing and duly registered, and (2) where there is an absence of any written contract. Both cases pertain to share tenancy contracts. Since the petitioners were not seeking a change to the leasehold system but only a change in the crop-sharing ratio within the share tenancy system, the one-year notice was not a condition precedent to filing their petition. The Court also noted that Section 14 had recently been amended by Republic Act No. 2263 , which eliminated the previous one-year notice requirement and provided for the application of its provisions to pending cases like this one. The case was ordered returned to the lower court for further proceedings.