GR L 22252; (October, 1968) (Digest)
G.R. No. L-22252; October 29, 1968
ELPIDIO MARCELO, petitioner, vs. REYNALDO MATIAS, PEDRO MANGAYAO, HONORIO GONZALES and HON. JOSE M. SANTOS, Presiding Judge, COURT OF AGRARIAN RELATIONS, Second Regional District, Cabanatuan City, respondents.
FACTS
Respondents-tenants Pedro Mangayao, Reynaldo Matias, and Honorio Gonzales filed a petition before the Court of Agrarian Relations (CAR Case No. 3012-NE ’62) seeking to change their tenancy relationship with petitioner-landowner Elpidio Marcelo from a sharing system to a leasehold system and to have the corresponding rentals fixed, pursuant to Section 14 of Republic Act No. 1199. Instead of filing an answer, petitioner filed an ejectment case against tenant Reynaldo Matias (CAR Case No. 2988-NE ’62) for harvesting bananas without consent and failing to deliver the landowner’s share. Petitioner also sought the ejectment of the other two tenants for allegedly failing to deliver his share of past harvests. The respondent court rendered a joint decision dismissing the ejectment case against Matias, upholding the constitutionality of Section 14 of RA 1199, declaring the relationship to be one of leasehold tenancy effective from specified dates, and fixing the corresponding rentals. Petitioner appealed, challenging only the constitutionality of Section 14.
ISSUE
Whether Section 14 of Republic Act No. 1199, which grants a tenant the right to change the tenancy contract from share tenancy to leasehold tenancy and vice versa, is constitutional.
RULING
Yes, Section 14 of Republic Act No. 1199 is constitutional. The Supreme Court affirmed the decision of the Court of Agrarian Relations, citing its consistent previous rulings upholding the validity of the questioned section. The Court held that the attribute of police power, reinforced by the protection to labor and social justice provisions of the Constitution, justifies such legislation. The measure serves public interest by aiding the economically underprivileged, and the means relied upon to attain this objective are neither unreasonable nor oppressive. As no new argument was presented to override previous decisions, the lower court’s decision was affirmed.