GLICERIO TINIO AND TEODORA LIMBAN, PETITIONERS-APPELLANTS, VS. RODRIGO MACAPAGAL, LUIS MARIN, ERNESTO PUNO, PABLO PUNO, TOMAS SAGUN, CIRILO MARIANO, VICTORIANO TUMIBAY, BUENAVEN…

Tinio versus Macapagal

The Case

This is a petition for review by certiorari of a decision of the Court of Agrarian Relations, brought by Glicerio Tinio and Teodora Limban, the landowners, against Rodrigo Macapagal and ten other tenants. The tenants had asked the agrarian court to change their tenancy contract from the share system to the leasehold system, relying on the unilateral right given to the tenant by Section 14 of Republic Act Number 1199, as amended. The landowners attack that grant of option as unconstitutional, as a denial of both due process and equal protection. The case matters because it is the Supreme Court's settled answer to that constitutional challenge: the tenant's right to change the system is a valid exercise of the police power of the State.

Procedural History

The tenants, Rodrigo Macapagal and ten others, filed a petition with the Court of Agrarian Relations for a change of their tenancy contract with the landowners from share to leasehold system, as provided in Section 14 of Republic Act Number 1199, as amended. The Court of Agrarian Relations granted the petition. The landowners then came to the Supreme Court by petition for review by certiorari, assailing the constitutionality of the grant of that option as a denial of both due process and equal protection. The Supreme Court affirmed the decision appealed from.

Facts

Glicerio Tinio and Teodora Limban are the landowners. Rodrigo Macapagal and ten other persons are their tenants: Luis Marin, Ernesto Puno, Pablo Puno, Tomas Sagun, Cirilo Mariano, Victoriano Tumibay, Lorenzo Macapagal, Buenaventura Talao, Victor Puyat and Pedro Mana.

The tenants held their land under a share tenancy contract. They wanted to change the arrangement to leasehold tenancy, and they invoked the right given to the tenant by Section 14 of Republic Act Number 1199, as amended, to make that change unilaterally.

They petitioned the Court of Agrarian Relations for the change, and the agrarian court granted their petition. The landowners resisted, arguing that giving the tenant the unilateral right to change the contract is unconstitutional, violating both due process and equal protection.

Issues

• Whether or not the grant to the tenant of the unilateral right to change the tenancy contract from share to leasehold system, under Section 14 of Republic Act Number 1199, as amended, denies due process of law.
• Whether or not that same grant denies the equal protection of the laws.

Applicable Provisions

Section 14 of Republic Act Number 1199, as amended, provides:

Section 14. Change of System. 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 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 the tenants invoked and the provision whose constitutionality the landowners assailed, because it gives the tenant the unilateral right to make the change.

Ruling

On the first issue, the Court held that the grant of the option does not deny due process. On the second issue, the Court held that it does not deny equal protection either. The Court noted that these objections have been repeatedly rejected by this Court upon the ground that the contested legal precept is a reasonable and valid exercise of the police power of the State, to afford a relief to a socio-economic problem existing in the Philippines. The Court found no justification to revise or otherwise alter its view thereon. In short, the challenged provision stands as a valid exercise of police power.

Doctrine

The unilateral right of the tenant, under Section 14 of Republic Act Number 1199, as amended, to change the tenancy contract from share tenancy to leasehold tenancy is a reasonable and valid exercise of the police power of the State, adopted to afford relief to a socio-economic problem existing in the Philippines. Being a valid exercise of police power, it does not violate due process of law. Neither does it violate the equal protection of the laws. A Bar answer should state the rule this way: the statutory option given to the tenant to change the system is constitutional, and the constitutional objections of due process and equal protection have been repeatedly rejected.

Disposition

The Supreme Court affirmed the decision of the Court of Agrarian Relations, with costs against the petitioners-appellants, so the tenants won and the change of their tenancy contract to leasehold stood.

Remember This

The one line to memorize: the tenant's unilateral right to change from share tenancy to leasehold tenancy under Section 14 of Republic Act Number 1199 is a valid exercise of the police power of the State and violates neither due process nor equal protection. Examiners use this case to test the constitutionality of agrarian reform measures and the police power as a ground for upholding social legislation.