Case Digest (G.R. No. L-21488)
Facts:
The case involves Lucila de la Paz as the petitioner and Marcos Papag as the respondent. The events took place in Sta. Rosa, Laguna, where Marcos Papag was a tenant under a share tenancy system for a 3.5-hectare riceland. On February 16, 1962, Papag sent a letter to de la Paz expressing his desire to change their tenancy arrangement to a leasehold system, a right provided under Section 14 of Republic Act No. 1199. De la Paz received this notice on February 19, 1962, but did not agree to the change. Instead, on March 7, 1962, she filed a petition with the Court of Agrarian Relations (CAR) in Sta. Cruz, Laguna (CAR Case No. 856), seeking arbitration. Papag responded by asking for the dismissal of the petition, claiming it was intended to delay the change he sought. While this case was pending, de la Paz initiated another case (CAR Case No. 1002) on September 17, 1962, to eject Papag, alleging that he failed to deliver her share of the rice crop from the August 1962 harvest. Dur...
Case Digest (G.R. No. L-21488)
Facts:
- Tenancy Relationship: Respondent Marcos Papag was a tenant under the share tenancy system on a 3.5-hectare riceland in Barrio Tagapo, Sta. Rosa, Laguna, owned by petitioner Lucila de la Paz.
- Change to Leasehold: On February 16, 1962, Papag sent a letter to de la Paz, notifying her of his intention to change their tenancy relationship from share tenancy to leasehold, as allowed under Section 14 of Republic Act No. 1199. The notice was received by de la Paz on February 19, 1962.
- Landowner's Opposition: Instead of agreeing, de la Paz filed a petition with the Court of Agrarian Relations (CAR) on March 7, 1962 (CAR Case No. 856), seeking arbitration. Papag countered by asking for the dismissal of the petition, alleging it was filed to delay the change.
- Second Case Filed: While CAR Case No. 856 was pending, de la Paz filed another case (CAR Case No. 1002) on September 17, 1962, seeking to eject Papag for allegedly failing to deliver her share of the rice crop from the August 1962 harvest.
- Partial Stipulation of Facts: During the joint hearing of the two cases on March 12, 1963, the parties agreed that the only issues were:
- The constitutionality of Section 14 of Republic Act No. 1199.
- If constitutional, the determination of the rental based on evidence.
- CAR Decision: On March 22, 1963, the CAR upheld the constitutionality of Section 14, dismissed both cases, and declared the tenancy relationship as leasehold effective April 1962. It also fixed separate rentals for the palagad and panahon crops.
- Appeal to Supreme Court: De la Paz appealed the CAR decision, raising issues on the constitutionality of Section 14 and the classification of the land as second class.
Issue:
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Ruling:
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Ratio:
- Constitutionality of Section 14: The right of a tenant to change from share tenancy to leasehold is a valid exercise of legislative power aimed at promoting agrarian reform and protecting tenant farmers.
- Land Classification: The term "years" in Section 46(a) of Republic Act No. 1199 refers to agricultural years, not calendar years. This interpretation aligns with the law's intent to base land classification on productivity over agricultural cycles.
- Rental Computation: Separate rentals for different crop periods (palagad and panahon) are justified to ensure fairness, as the yields for these crops vary significantly. The CAR's method of computation was reasonable and in accordance with the law.