GR L 1867; (April, 1950) (Digest)
G.R. No. L-1867; April 8, 1950
CARMEN DE LA PAZ VDA. DE ONGSIAKO, petitioner, vs. TEODORICO GAMBOA and PANTALEON GAMBOA ET AL., respondents.
FACTS
Petitioner-landowner and respondent-tenants entered into tenancy contracts in June-July 1946 under the then-governing Act No. 4054, as amended by Commonwealth Act No. 178. The contracts stipulated a 50-50 division of the crop, with the landowner shouldering planting expenses and the tenants defraying harvesting expenses. On September 30, 1946, Republic Act No. 34 took effect, amending the prior tenancy law to provide for a more favorable 55-45 crop division in favor of tenants. During the liquidation of the 1946-1947 harvest, the tenants sought application of the new law. The Tenancy Law Enforcement Division and, on appeal, the Court of Industrial Relations, ruled that the crop division should be 55-45 in favor of the tenants under Republic Act No. 34, notwithstanding the prior contracts.
ISSUE
Whether Republic Act No. 34, which provides for a more favorable crop division for tenants, applies to tenancy contracts executed before its effectivity, and if so, whether such application constitutes an unconstitutional impairment of the obligation of contracts or gives the law an invalid retroactive effect.
RULING
Yes, Republic Act No. 34 applies. The Supreme Court affirmed the decision of the Court of Industrial Relations. The law is a valid exercise of the State’s police power to promote social justice and the economic security of tenants, as mandated by the Constitution. It is not an ex post facto law, as such prohibition applies only to criminal matters. Neither does it unconstitutionally impair the obligation of contracts, because contracts are subject to legislation enacted under the police power for the public welfare. The stipulation in the prior contracts for a 50-50 division, being contrary to the public policy established by the new law, is invalid. The Court also declined to review the factual finding on planting expenses, as only questions of law may be raised in such appeals.
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