G.R. No. L-21012 February 25, 1967
GLICERIO TINIO and TEODORA LIMBAN, petitioners-appellants, vs. RODRIGO MACAPAGAL, LUIS MARIN, ERNESTO PUNO, PABLO PUNO, TOMAS SAGUN, CIRILO MARIANO, VICTORIANO TUMIBAY, BUENAVENTURA TALAO, VICTOR PUYAT, PEDRO MANA and The Honorable JOSE M. SANTOS, Presiding Judge of the Court of Agrarian Relations, Second Regional District, Cabanatuan City, respondents-appellees.

FACTS

Petitioners Glicerio Tinio and Teodora Limban were landowners. Respondents Rodrigo Macapagal and ten other persons were their tenants. The respondents filed a petition before the Court of Agrarian Relations seeking to change their tenancy contract with the petitioners from a share tenancy system to a leasehold system. This petition was based on Section 14 of Republic Act No. 1199, as amended (the Agricultural Tenancy Act), which grants the tenant the unilateral right to effect such a change. The Court of Agrarian Relations granted the respondents’ petition. The petitioners then appealed to the Supreme Court, challenging the constitutionality of Section 14 of Republic Act No. 1199.

ISSUE

Whether Section 14 of Republic Act No. 1199, as amended, which grants a tenant the unilateral right to change the tenancy contract from share to leasehold, is constitutional, or whether it constitutes a denial of due process and equal protection of the laws.

RULING

The Supreme Court affirmed the decision of the Court of Agrarian Relations. The Court held that Section 14 of Republic Act No. 1199 is a constitutional and valid exercise of the police power of the State. The grant of a unilateral option to the tenant to change the tenancy system is a reasonable measure intended to address a socio-economic problem in the Philippines. The Court rejected the petitioners’ arguments that the provision denies due process and equal protection, citing its previous rulings which have consistently upheld the constitutionality of the said provision. Costs were imposed on the petitioners-appellants.