Facts:

The case involves Mateo de Ramas as the petitioner and Geronimo B. Ramos as the respondent. The events took place in Muzon, Naic, Cavite, where Ramos was a tenant of Ramas, cultivating a 2.5-hectare land under a verbal share tenancy agreement with a 70-30 sharing ratio in favor of Ramas. On June 22, 1960, Ramos expressed his desire to change their tenancy contract from share tenancy to leasehold tenancy, which Ramas refused, insisting on maintaining the original agreement. Consequently, on May 23, 1961, Ramos filed a petition with the Court of Agrarian Relations, seeking to change the contract in accordance with Section 14 of Republic Act No. 1199, as amended. Ramas opposed the petition, claiming it violated their gentleman's agreement. During the proceedings, Ramos requested to suspend the case due to the pending constitutionality challenge of Section 14 before the Supreme Court in the case of Juliano vs. CAR, which was denied. On December 14, 1961, Ramos presented his e...

Facts:

1. Parties Involved:

   • Petitioner: Mateo de Ramas (landlord).
   • Respondent: Geronimo B. Ramos (tenant).

2. Tenancy Agreement:

   • Ramos was the tenant of de Ramas on a 2.5-hectare land in Muzon, Naic, Cavite.
   • The tenancy was governed by a verbal share tenancy contract with a 70-30 sharing arrangement (70% to the landlord, 30% to the tenant).

3. Request for Change in Tenancy:

   • On June 22, 1960, Ramos informed de Ramas of his desire to change the tenancy contract from share tenancy to leasehold tenancy.
   • De Ramas refused, insisting on maintaining the 70-30 sharing basis.

4. Filing of Petition:

   • On May 23, 1961, Ramos filed a petition with the Court of Agrarian Relations (CAR) seeking to change the tenancy contract to leasehold under Section 14 of Republic Act No. 1199.
   • De Ramas opposed the petition, arguing it violated their "gentleman's agreement."

5. Procedural Developments:

   • Ramos moved to suspend the proceedings pending the Supreme Court's decision on the constitutionality of Section 14 of RA 1199 in another case (Juliano vs. CAR).
   • The motion was denied, and the CAR proceeded with the case.
   • Ramos presented evidence, but de Ramas waived his right to present evidence, opting to appeal any adverse decision.

6. CAR Decision:

   • On March 1, 1962, the CAR upheld the constitutionality of Section 14 of RA 1199 and granted Ramos's petition to change the tenancy to leasehold.

7. Appeal to the Supreme Court:

   • De Ramas filed a petition for certiorari, challenging the CAR's decision and arguing that Section 14 of RA 1199 was unconstitutional for impairing the obligation of contracts.

Issue:

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Ruling:

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Ratio:

1. Presumption of Constitutionality:

   • Laws are presumed valid until declared unconstitutional. Courts are duty-bound to enforce them unless otherwise ruled.

2. Police Power and Social Justice:

   • The State has the authority to enact laws under its police power to promote social justice, protect agricultural laborers, and regulate landlord-tenant relationships.
   • Section 14 of RA 1199 is a legitimate exercise of this power, aimed at improving the economic condition of tenants and ensuring their security of tenure.

3. Impairment of Contracts:

   • While Section 14 affects existing tenancy contracts, it is not an unreasonable or oppressive impairment. The reduction of the landlord's share from 30% to 25% under leasehold tenancy is justified by the benefits it provides to tenants and the broader societal goal of promoting social justice.

4. Historical Context and Legislative Intent:

   • The provision is rooted in the historical plight of tenants, particularly in Central Luzon, where tenant uprisings highlighted the need for agrarian reform.
   • The law seeks to address the exploitation of tenants and provide them with incentives to improve their economic standing.

5. Constitutional Mandate:

   • The Constitution mandates the promotion of social justice and the protection of agricultural laborers. Section 14 aligns with this directive by empowering tenants to improve their lot through leasehold tenancy.

Conclusion:

The Supreme Court affirmed the decision of the Court of Agrarian Relations, holding that Section 14 of RA 1199 is constitutional and valid. The provision is a reasonable exercise of the State's police power to promote social justice and improve the economic condition of tenants, without unreasonably impairing contractual obligations.