Case Digest (G.R. No. L-21488)
Facts:
Lucila de la Paz v. Court of Agrarian Relations and Marcos Papag, G.R. No. L-21488, October 14, 1968, Supreme Court En Banc, Makalintal, J., writing for the Court.
Petitioner Lucila de la Paz was the landowner of a 3½-hectare riceland in Barrio Tagapo, Sta. Rosa, Laguna; respondent Marcos Papag was her tenant working the land under a share-tenancy arrangement.
On February 16, 1962 Papag served a written notice invoking Section 14, Republic Act No. 1199 to convert the tenancy from share tenancy to leasehold; petitioner received the notice on February 19, 1962 but opposed the change. Instead of agreeing, petitioner filed CAR Case No. 856 on March 7, 1962 before the Court of Agrarian Relations (Fifth Regional District, Sta. Cruz, Laguna) seeking an order for confrontation and "arbitration" between the parties. The tenant answered and moved to dismiss for delay.
While CAR Case No. 856 was pending, petitioner filed CAR Case No. 1002 on September 17, 1962 seeking ejectment of the tenant for alleged failure to deliver her share of the August 1962 rice harvest. At a joint hearing (March 12, 1963) the parties stipulated that the only disputes were (1) the constitutionality of Sec. 14, R.A. 1199 and (2) if constitutional, the rental to be set by the court.
The Court of Agrarian Relations, in a decision dated March 22, 1963, upheld the constitutionality of Sec. 14 and dismissed the two cases against the tenant, declaring the relation leasehold effective April 1962 (start of the agricultural season for the panahon crop). The CAR fixed separate rentals for the palagad and panahon crops (13½ cavans and 18 cavans of palay respectively), to be paid within ten days from threshing, subject to future adjustment for improvements.
Petitioner’s motion for reconsideration was denied. She sought relief in this Court by petition for certiorari with an application for a writ of preliminary injunction; on August 8, 1963 this Court issued the writ restraining respondents from executing the CAR decisions. In the present appeal petitioner again challenged the constitutionality of ...(Pro-only)
Issues:
- Is Section 14 of Republic Act No. 1199 constitutional?
- For purposes of classification of ricelands and computation of rental under Section 46(a) of R.A. 1199, does the term "years" refer to calendar years or to agricultural/harvest years?
- Did the Court of Agrarian Relations err in classifying the subject land as second class and in fixing separate rental...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)