PILAR REYES, PETITIONER, VS. HON. JOSE M. SANTOS, AS ASSOCIATE JUDGE OF THE COURT OF AGRARIAN RELATIONS, STA. CRUZ, LAGUNA, AND MAXIMINO ENRIQUEZ, RESPONDENTS.

Reyes versus Santos

The Case

This is a petition by Pilar Reyes, a landowner in Calamba, Laguna, against Judge Jose M. Santos of the Court of Agrarian Relations and her tenant, Maximino Enriquez. The action began as a petition in the Court of Agrarian Relations, where the landowner sought to preserve the original share tenancy arrangement and to challenge the constitutionality of the provision of the Agricultural Tenancy Law that allows a tenant to change the tenancy system from share tenancy to leasehold tenancy. The case matters because it is one of the line of decisions in which the Supreme Court settled that this statutory privilege of the tenant does not offend the Constitution, a doctrine every agrarian law candidate must know.

Procedural History

Pilar Reyes filed a petition in the Court of Agrarian Relations of Sta. Cruz, Laguna, asking for an interlocutory order dividing the existing palay crop pending final determination of the controversy over the constitutionality of the provision allowing the change of tenancy. The court issued the interlocutory order prayed for, and the parties then stipulated on the facts. On June 6, 1962, the court dismissed the petition for lack of merit and ruled that the tenant had the right, upon proper notice, to change the prevailing tenancy system to leasehold tenancy. The landowner appealed, and the case reached the Supreme Court by appeal by certiorari, raising the sole question of the validity of Section 14 of the Agricultural Tenancy Law, as amended.

Facts

Pilar Reyes owned a parcel of land of about two hectares in barrio Lawa, Calamba, Laguna. The land was worked by Maximino Enriquez under a verbal agreement of tenancy, under which they shared both the expenses and the harvest equally.

On November 18, 1960, one month before the next agricultural year started, the tenant notified the landowner that he was changing their relationship from share tenancy to leasehold. On December 17, 1960, the landowner informed the tenant that she was opposed to the change.

On May 2, 1961, the landowner filed her petition in the Court of Agrarian Relations, asking that the existing palay crop be divided fifty percent for the tenant, twenty percent for the landowner, and thirty percent deposited with the municipal treasurer of Calamba, pending final determination of the controversy concerning the constitutionality of the provision of the Agricultural Tenancy Law giving the tenant the privilege to change the agreement from share tenancy to leasehold tenancy, which was then under consideration by the Supreme Court in another case, so that should the provision be declared unconstitutional the parties would respect their original sharing agreement.

Issues

• Whether or not Section 14 of the Agricultural Tenancy Law, as amended, is void because it results in deprivation of property without due process of law.
• Whether or not the same provision impairs the obligation of contracts.
• Whether or not the same provision constitutes class legislation.

Applicable Provisions

Section 14 of the Agricultural Tenancy Law, as amended, provides:

The tenant shall have the right to change the tenancy contract from one of share tenancy to leasehold tenancy and vice versa and from one crop sharing arrangement to another of the share tenancy. If the share tenancy contract is in writing and is duly registered, the right to change from one crop sharing arrangement to another may be exercised at least one month before the beginning of the next agricultural year after the expiration of the period of the contract. In the absence of any registered written contract, the right may be exercised at least one month before the agricultural year when the change shall be effected.

This is the provision whose constitutionality the landowner challenged and which the Court upheld.

Ruling

The Court resolved all three issues against the landowner and upheld the provision. On due process, the Court held that the statutory privilege of the tenant to change the tenancy system does not amount to a deprivation of property without due process of law. On the impairment of contracts, the Court held that the provision does not impair the obligation of contracts. On class legislation, the Court held that the provision does not constitute class legislation.

The Court noted that the same questions had been raised in other cases decided by the Court, and that the constitutionality of the law had been repeatedly upheld, citing its earlier decisions in Ramas versus Court of Agrarian Relations, Macasaet versus Court of Agrarian Relations, Uichanco versus Gutierrez, Gamboa versus Pallarca, and Cuizon versus Ortiz. The Court therefore affirmed the decision of the lower court, with costs against the appellant.

Doctrine

Section 14 of the Agricultural Tenancy Law, as amended, is constitutional. The right of the tenant to change the tenancy contract from share tenancy to leasehold tenancy, and vice versa, and from one crop sharing arrangement to another, upon the notice required by the provision, does not deprive the landowner of property without due process of law, does not impair the obligation of contracts, and does not constitute class legislation. A Bar candidate should state the rule as the Court stated it: the tenant shall have the right to change the tenancy contract from one of share tenancy to leasehold tenancy and vice versa, and this statutory privilege has been repeatedly sustained against constitutional attack.

Disposition

The Supreme Court affirmed the decision of the Court of Agrarian Relations, with costs against the appellant, Pilar Reyes.

Remember This

The one line to memorize: the tenant's statutory right to change share tenancy to leasehold tenancy is constitutional and has been repeatedly upheld. Examiners use this case to test the constitutionality of Section 14 of the Agricultural Tenancy Law against due process, impairment of contracts, and class legislation.