G.R. No. L-26551 - People vs. Almuete

The accused—Wenceslao Almuete, Fernando Fronda, Cipriano Fronda, and Fausto Durion—were charged with violating Section 39 of the Agricultural Tenancy Law.
It was alleged that, in December 1963 in Munoz, Nueva Ecija, the four tenants, without the landowner Margarita Fernando’s notice or consent, pre-threshed a portion of their respective harvests.
Specifically, each tenant allegedly pre-threshed five (5) cavans of palay, causing damage amounting to P187.50, computed at P12.50 per cavan.

Upon arraignment, the accused pleaded not guilty.
They initially filed a motion for a bill of particulars specifying the exact date of the commission of the offense, which was denied because their plea had already been entered.
Subsequently, the accused filed a motion to quash the information, arguing:

The lower court denied the motion for bill of particulars but eventually granted the motion to quash by dismissing the information on August 11, 1966.
The court reasoned that the information was deficient:

It failed to describe the circumstances under which the palay was found in the tenants’ possession.
It did not specify the agreed date for threshing the harvest.
It did not allege that the palay pre-threshed exceeded ten percent of the tenant’s net share based on the previous normal harvest.

The prosecution relied on Section 39 and Section 57 of Republic Act No. 1199 (as amended by Republic Act No. 2263):

Section 39 prohibited reaping or threshing a portion of the crop before the officially set date unless under specific conditions (i.e., tenant needing food and obtaining notice to the landholder, provided that such pre-threshing did not exceed ten percent of the net share).
Section 57 prescribed the penalty for violation of these provisions as a fine not exceeding two thousand pesos, imprisonment not exceeding one year, or both.

The Solicitor General asserted that the elements of the offense were fully alleged in the information.

The Court noted that in People vs. Adillo, it was held that Section 39 was impliedly repealed by the Agricultural Land Reform Code of 1963, as amended by Republic Act No. 6389 and implemented by Presidential Decrees Nos. 2, 27, and 316.
The repeal was based on the rationale that:

Section 39 was premised on the rice share tenancy system.
The Agricultural Land Reform Code introduced the leasehold system, thereby abolishing share tenancy except under certain conditions.

It was highlighted that Section 39 did not form part of the new Code, and Section 172 of the Code expressly repealed conflicting provisions of previous laws.
Moreover, legislative instruments such as PD Nos. 2, 27, and 316, and provisions within the Code of Agrarian Reforms, reflected a policy change toward non-penalization of pre-reaping or pre-threshing actions under the new leasehold regime.

The appellees argued that the Municipal Court should have jurisdiction due to the relatively low penalties prescribed for the offense.
The Court, however, reaffirmed that the Court of First Instance had concurrent jurisdiction in cases with penalties exceeding certain thresholds (i.e., imprisonment of more than six months or fines exceeding two hundred pesos), thereby dismissing the jurisdictional contention.

Whether the information charged under Section 39 of the Agricultural Tenancy Law sufficiently alleged facts constituting the offense.
Whether there was an existent penal law applicable to the act of pre-threshing under the circumstances described.
Whether the lower court had jurisdiction over the offense given the limitations on jurisdiction as raised by the appellees.
Whether Section 39 of the Agricultural Tenancy Law remained applicable or had been repealed by subsequent agrarian reform legislation (specifically the Agricultural Land Reform Code and the Code of Agrarian Reforms).