A.C. No. 3319 - Ui vs. Bonifacio

Under Section 36(1) of Republic Act No. 3844 (the Agricultural Land Reform Code), a landowner could eject an agricultural tenant on the ground that the owner intended to personally cultivate the land.
On September 10, 1971, Republic Act No. 6389 was enacted amending RA 3844 by eliminating personal cultivation as a ground for ejectment.
The controversy centers on whether this amendment should be given retroactive effect covering cases filed before the new law took effect.

Almario Gatchalian is the registered owner of a two-hectare parcel of riceland in Bulacan.
Hospicio Nilo, who had been an agricultural share-tenant since the agricultural year 1964-65, was involved in an ejectment suit filed on March 7, 1968 by Gatchalian invoking personal cultivation under the old law.
Nilo countered that the ejectment suit was a retaliatory act because he had elected the leasehold system.
The Court of Agrarian Relations found a bona fide intention by Gatchalian to personally cultivate the land, a finding later affirmed by the Court of Appeals.
Nilo’s motion for reconsideration arguing that RA 6389 eliminated personal cultivation as a valid ground for ejectment was denied on the basis that the law did not have retroactive application.

Fortunato Castro, the landowner of a 6,941-square-meter lot in Pulilan, Bulacan, initiated an ejectment suit to remove his tenant, Juan Castro, on the ground of personal cultivation.
The tenant contested the ejectment by challenging Castro’s fitness and alleging, among other defenses, that the petition was prejudiced by the subsequent amendment of the ejectment ground.
Following the amendment through RA 6389, the lower court dismissed Castro’s complaint, and his subsequent motions for reconsideration were denied.
Castro raised the issue of the alleged constitutionality of Section 7 of RA 6389, which amended the provisions on personal cultivation.

Both cases were heard jointly by the Supreme Court because they involved the identical factual controversy regarding personal cultivation as a ground for ejectment, and specifically the retroactive effect of RA 6389.
The central legal question became whether the repeal of personal cultivation is applicable to cases that were pending before the enactment of RA 6389.

Should the amendment in RA 6389, which eliminated personal cultivation as a ground for ejectment, be given retroactive effect to cover ejectment cases that were filed under the old law before its enactment?

Does Section 7 of RA 6389, which mandates that a landholding be declared suitable for urban or other non-agricultural purposes with corresponding provisions for disturbance compensation, violate any constitutional guarantees, particularly if it impairs the rights of small landowners?

How should the general rule that laws operate prospectively, unless a clear intent for retroactivity is expressed, be applied in these cases?