Facts:
**Case 1: G.R. NO. L-34586**
– Almario Gatchalian owned a parcel of riceland in San Rafael, Bulacan.
– Hospicio Nilo had been an agricultural share-tenant on the land since 1964-65.
– On February 22, 1967, Nilo filed a petition for leasehold system implementation.
– On March 7, 1968, Gatchalian filed an ejectment suit against Nilo citing personal cultivation under Sec. 36(1) of Republic Act No. 3844.
– Nilo claimed the ejectment was retaliatory for his election of the leasehold system.
– The Court of Agrarian Relations found Gatchalian had a genuine intention to cultivate the land.
– Nilo appealed to the Court of Appeals, which affirmed the Agrarian Relations Court’s decision.
– Nilo filed a motion for reconsideration arguing that Sec. 7 of Republic Act No. 6389, effective September 10, 1971, eliminated personal cultivation as grounds for ejectment.
– The Court of Appeals denied the motion, ruling that Republic Act No. 6389 was not retroactive.
**Case 2: G.R. NO. L-36625**
– Fortunato Castro owned a landholding in Pulilan, Bulacan.
– Castro filed a complaint for ejectment against his tenant, Juan Castro, citing personal cultivation.
– Juan Castro argued that Fortunato was unfit to personally cultivate and that the petitioner did not own the land.
– After Republic Act No. 6389 took effect, Juan Castro moved for the dismissal of the complaint.
– The Court of Agrarian Relations dismissed Fortunato’s complaint.
– Fortunato Castro appealed to the Court of Appeals, which certified the appeal to the Supreme Court due to the constitutional challenge raised.
– Fortunato questioned the constitutionality of Sec. 7 of Republic Act No. 6389.
Issues:
1. Whether Republic Act No. 6389 should be applied retroactively to cases filed before its effectivity on September 10, 1971.
2. Whether the provision eliminating personal cultivation as a ground for ejectment is unconstitutional.
Court’s Decision:
**Issue 1: Retroactivity**
– Traditionally, laws operate prospectively unless there is an express provision for retroactive effect (Article 4 of the New Civil Code).
– The Court reviewed statutory principles and legislative intent.
– The court emphasized that statutes are generally presumed to be prospective.
– The Court concluded that Republic Act No. 6389, which lacks an express retroactive provision, should not apply retroactively.
**Issue 2: Constitutionality**
– The Court found no constitutional infirmity in Sec. 7 of Republic Act No. 6389.
– Agrarian reform is consistent with constitutional mandates promoting social justice and equitable land distribution.
– Fortunato Castro’s separate argument on constitutionality was rejected, and the dismissal of his case was reversed for further proceedings.
Doctrine:
1. **Prospective Application of Laws**: Laws are to be construed as having only a prospective operation unless expressly declared to be retroactive.
2. **Equitable Land Reform**: Statutory changes deriving from social reform statues, like Republic Act No. 6389, must be interpreted to promote equitable land ownership and social justice.
Class Notes:
– **Statutory Construction**: As per Article 4 of the New Civil Code, laws are prospective in application unless retroactivity is explicitly mentioned.
– **Personal Cultivation Ground**: Prior to its repeal by Republic Act No. 6389, personal cultivation was a valid ground for ejectment under Republic Act No. 3844.
– **Social Justice Consideration**: Property laws, especially under agrarian reform laws, should be interpreted to ensure fairness both to tenants and small landowners.
Historical Background:
– Republic Act No. 3844 (Agricultural Land Reform Code of 1963) allowed ejectment for personal cultivation.
– Republic Act No. 6389 (1971) amended the Agricultural Land Reform Code to eliminate personal cultivation as grounds for ejectment, reflecting an evolution in land reform aimed toward enhancing the rights and security of tenants while balancing the rights of small landholders.
These cases reflect the dynamic interplay between legislative reforms and constitutional mandates in the Philippines aimed at achieving social justice.
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