G.R. No. L-20407 March 31, 1966
PASTOR GAMBOA, petitioner, vs. DIONISIO PALLARCA, and the Honorable JOSE M. SANTOS, Presiding Judge, CAR, 2nd Regional District, Cabanatuan City, respondents.

FACTS

Respondent Dionisio Pallarca is the share tenant of petitioner Pastor Gamboa on a 2-1/2 hectare riceland in Sto. Tomas, Jaen, Nueva Ecija, since the agricultural year 1957-1958. Their sharing ratio was fifty-fifty, with the tenant contributing labor, work animals, farm implements, and expenses for final harrowing, and the landholder contributing the land and expenses for transplanting. There was no registered written tenancy contract. On April 11, 1961, the tenant sent a written notice by registered mail to the landholder informing him of his desire to change their tenancy system from share to leasehold tenancy, effective the agricultural year 1961-1962, which started in June 1961. The notice was received on April 14, 1961, more than one month before the start of the agricultural year. The landholder did not agree to the change. The tenant filed a petition for the change of the tenancy contract in the Court of Agrarian Relations on December 19, 1961, also praying for the immediate threshing and temporary liquidation of the harvest for that year. The landholder, in his answer, defended that the tenancy relationship no longer existed because the tenant had voluntarily surrendered and abandoned the landholding after the 1960-1961 agricultural year and later forcibly ejected his successor. He also contended that Section 14 of Republic Act 1199, as amended by Republic Act 2263, which grants the tenant the right to change the tenancy contract, was unconstitutional. The lower court found that a tenancy relationship existed during the 1961-1962 agricultural year, declared the change to leasehold tenancy effective, fixed the annual rental, and ordered the release of deposited palay. The landholder’s motion for reconsideration was denied, prompting this appeal via certiorari.

ISSUE

The sole issue to be resolved is the constitutionality of Section 14 of Republic Act 1199, as amended by Republic Act 2263.

RULING

The petition for certiorari is denied, and the decision appealed from is affirmed. The Supreme Court upheld the constitutionality of Section 14 of Republic Act 1199, as amended. The Court cited its previous decisions in Ramas vs. Court of Agrarian Relations (G.R. No. L-19555, May 29, 1964), Macasaet vs. Court of Industrial Relations, et al. (G.R. No. L-19750, July 17, 1964), and Uichangco vs. Gutierrez, et al. (G.R. Nos. L-20275-20279, May 31, 1965), where the constitutionality of the same provision was sustained against challenges that it was not a valid exercise of police power and that it violated the equal protection, due process, and impairment of contract clauses of the Constitution. The palay ordered deposited during the pendency of the case should be released to the parties entitled thereto in accordance with the lower court’s decision. Costs are against the petitioner.