G.R. No. L-20589-90 - Del Rosario vs. De los Santos

Ernesto del Rosario, the petitioner and landowner, initiated the petition for review to challenge the validity of Section 14 of the Agricultural Tenancy Act of 1955.
Section 14 provides that a tenant may change the tenancy contract from share tenancy to leasehold tenancy (and vice versa) as well as between different crop-sharing arrangements.

On April 28, 1961, two petitions were filed by respondents Victorino de los Santos and Tomas de los Santos, who were tenants under Ernesto del Rosario, expressing their desire to change their tenancy arrangement from share tenancy to leasehold tenancy in accordance with Section 14.
In the answer submitted on May 5, 1961, petitioner (landowner del Rosario) challenged the constitutionality of Section 14, arguing that it impaired the obligations of an existing contract and affected the freedom of contract guaranteed under due process.
On October 26, 1962, the Court of Agrarian Relations rendered a joint decision on the two petitions from the tenants, dismissing the claim of unconstitutionality and declaring the relationship between the parties as one of leasehold tenancy effective for the agricultural year 1961-1962.
Following the decision of the Court of Agrarian Relations, petitioner del Rosario then filed this petition for review.

The Agricultural Tenancy Act of 1955 was enacted in response to long-standing agrarian issues and aimed at addressing the oppressive conditions historically experienced by agricultural laborers.
The Act was grounded on the principles of social justice and the protection to labor as enshrined in the Philippine Constitution—ensuring that those with less in life are accorded more in the law.
Prior jurisprudence, including decisions in De Ramas and Ilusorio, had upheld Section 14 as a valid exercise of the State’s police power, aimed at balancing the rights of tenants and landlords in the context of agricultural reform.

A secondary issue raised pertained to whether the use of additional farm equipment (a tractor, alongside traditional implements like the carabao) could disqualify a landowner from personally cultivating his land and ejecting his tenants under the Agricultural Tenancy Act.
The Court of Agrarian Relations found that petitioner del Rosario did not possess a bona fide intention to cultivate the land personally—a factual finding supported by substantial evidence and thus not subject to disturbance on appeal.

Whether Section 14, which permits tenants to change their tenancy system between share and leasehold arrangements, impermissibly impairs the obligations of an existing contract.
Whether the provision violates the freedom of contract protected by the due process clause of the Constitution.

Whether the utilization of a tractor, in addition to traditional farm implements and a carabao, constitutes grounds for disqualifying a landowner from undertaking personal cultivation and proceeding with the ejectment of his tenants.
The issue was rendered academic by the court’s finding that petitioner did not intend to cultivate his land personally.