G.R. No. 200544 - Ilocos Norte Electric Cooperative vs. Cynthia Gertrudes Andres-Ranjo, Elma Andres Maraaan, represented by William G. Maraaan

This case involves two petitions for review challenging a joint decision rendered by the respondent Court of Appeals.
The petitions arise from a dispute between tenant farmers and the registered respondent-landholder, Enrique Zobel, concerning the right of ejectment.
The controversy centers on whether the tenant farmers, who till portions of Hacienda Bigaa in Calatagan, Batangas, should be evicted despite their established tenancy.

Petitioner Zoila de Chavez, along with other tenant petitioners—Bartolome Dimaala, Rufo Garcia, Paulino Esguerra, Fernando Veroya, Wilson Zapatero, Rufino Zapatero, Almario Alab, Roman Veroya, and Romana Vizconde—filed petitions for review.
Respondent Enrique Zobel, as the registered owner, sought to evict the tenant petitioners by invoking provisions of Republic Act No. 1199.
Initially, the Court of Agrarian Relations dismissed the petition for ejectment, finding that the claimed intent to mechanize (and thereby justify eviction) was unconvincing.
The Court of Appeals subsequently reversed this decision, thus granting the petition for ejectment and prompting the present petitions for review.

At the hearing on July 15, 1963, the litigants stipulated the existence of a clear landholder–tenant relationship.
The respective areas cultivated by each tenant were enumerated as follows:

The dispute involves the interpretation and application of Republic Act No. 1199, which provides incentives for land mechanization.
Integral to the case is Presidential Decree No. 27 issued on October 21, 1972, which decrees the emancipation of tenant farmers by transferring to them the ownership of the land they till.
The decree is a manifestation of the state's policy as set forth in the Revised Constitution, particularly embodying the objective of agrarian reform aimed at emancipating tenants from bondage to the soil.

The case is set against the backdrop of the long-standing tenancy problem in the Philippines, a situation that has been a source of social injustice and feudalistic exploitation.
The jurisprudence and legislative reforms, including constitutional mandates and agrarian reform laws, have consistently aimed at redressing the inequities inherent in the agrarian setup.
The historical evolution—from the early concerns of patriots like Jose Rizal to the comprehensive statutory and constitutional measures—is highlighted to provide context for the mandate of tenant emancipation.

Whether this Honorable Tribunal is bound by the cardinal policy of tenant emancipation under Presidential Decree No. 27 as integrated in the Revised Constitution when determining the right to eject tenant farmers.

Whether the petitioner's small landholdings, as stipulated in the case, qualify for the protections under the PD No. 27.
Whether the Court of Appeals erred in granting the petition for ejectment contrary to the agrarian reform mandate provided by both the Presidential Decree and the Revised Constitution.
The extent to which the state’s agrarian reform program, which aims at emancipating the tenant farmer, supersedes conflicting provisions such as those contained in Republic Act No. 1199.