GR L 20275 79; (May, 1965) (Digest)
G.R. No. L-20275-79 May 31, 1965
VIRGINIA B. UICHANCO, EDUARDO LIM and MERCEDES B. UICHANCO, petitioners, vs. FIDEL GUTIERREZ, MARCOS DE LA PEÑA, GERARDO PECHO, REYNALDO MERCADO and FLAVIANO EVANGELISTA, respondents.
FACTS
The five respondents were share tenants of the petitioners, who owned small rice farms in Calamba, Laguna. Their verbal tenancy agreement involved sharing production expenses and dividing the harvest on a fifty-fifty basis. In 1960, the tenants demanded the conversion of their tenancy relationship from share tenancy to leasehold tenancy, invoking the right granted by Section 14 of Republic Act No. 1199, as amended. The landowners opposed this demand, leading to five litigations. The Court of Agrarian Relations upheld the tenants’ demand and rendered judgment in their favor. The landowners appealed to the Supreme Court, raising the sole issue of the constitutionality of Section 14 of Republic Act No. 1199, as amended.
ISSUE
Whether or not Section 14 of Republic Act No. 1199, as amended, is constitutional.
RULING
The Supreme Court upheld the constitutionality of Section 14 of Republic Act No. 1199, as amended. The Court affirmed the appealed decision of the Agrarian Court. The Court noted that the constitutional question had already been resolved in previous decisions (Juliano v. Court of Appeals, G.R. No. L-17627; Rams v. Court of Agrarian Relations, L-19555, May 29, 1964; Macasaet v. Court of Agrarian Relations, L-19750, July 17, 1964), which upheld the validity of the statute. The Court further reasoned that since the parties entered into the verbal tenancy relationship in 1956 or later, the law (Section 14) giving the tenant the right to demand a leasehold arrangement was already in existence and should be deemed included in their contract of tenancy; thus, the landlord could not complain about interference with or impairment of the contract by the law. The Court also noted in passing that the Land Reform Code (Republic Act 3844) abolished agricultural share tenancy and reaffirmed the tenant’s privilege to elect the leasehold system. The sole issue presented being the validity of the law, and no error having been shown in the Agrarian Court’s computation of rental and distribution of harvest, the decision was affirmed.