Case Digest (G.R. No. L-1505)
Facts:
Valentin Camacho, Bonifacio Macarahas, et al. v. Court of Industrial Relations, Angeles Canson and Teresa Melgar de Carretero, G.R. No. L-1505. May 12, 1948, Supreme Court En Banc, Feria, J., writing for the Court.The petitioners were tenants who cultivated palay on haciendas owned by the respondents in Sta. Barbara, Pangasinan for the agricultural year 1946–1947. The Tenancy Law Enforcement Division of the Department of Justice (the Tenancy Division) originally ordered that the crop be divided 70% to the landowners and 30% to the tenants, after deducting harvesting and threshing expenses, applying the share-basis provisions as amended by Republic Act No. 34 (amendatory of Act No. 4054).
The Court of Industrial Relations (CIR) reversed the Tenancy Division. The CIR held that an oral contract embodying the customary tenancy-sharing arrangement between the parties controlled under Section 8 of Act No. 4054, and relied on Commonwealth Act No. 53, Section 1, which permits the tenant’s testimony as prima facie evidence of an unwritten share-tenancy contract. The CIR also concluded that Republic Act No. 34 became effective in Pangasinan only upon Presidential Proclamation No. 14 (the CIR treated that proclamation as initiating the law’s force in provinces not previously covered), and therefore the 70–30 rule could not be applied to the 1946–1947 crop.
The parties had stipulated facts before the CIR: the palay had been planted in May–July 1946 and harvested from October–December 1946 (and even into January 1947); the tenants owned work animals and necessary implements and had borne the cost of plowing and cultivation; the landlords had supplied seed; and harvest and threshing expenses had been deducted from the gross produce. The CIR ordered division under the old custom; the Tenancy Division’s order applying RA 34 was set aside.
The petition came to the Supreme Court by appeal from the decisio...(Subscriber-Only)
Issues:
- In the Province of Pangasinan, where Act No. 4054 had been proclaimed effective in 1937, may an oral share-tenancy contract be deemed valid and binding under Commonwealth Act No. 53, Section 1, so as to govern the 1946–1947 tenancy relations between the parties?
- Was Republic Act No. 34 (amending section 8 of Act No. 4054) operative as to the 1946–1947 palay crop — i.e., did it become effective in Pangasinan upon its passage on September 30, 1946 (or otherwise before harvest) and, if applied, would such application be an unlawful ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)