DOROTEO ONOFRE, ET AL., PETITIONERS, VS. HON. PASTOR P. REYES, ET AL., RESPONDENTS.

Onofre versus Reyes

The Case

This is a petition by Doroteo Onofre and eight other tenant farmers against their landholder, Ramon Cabral, and against the Court of Agrarian Relations that ruled in his favor. The tenants asked the agrarian court to compel the landholder to agree to a change in their crop-sharing arrangement, from forty-five fifty-five to thirty seventy, invoking section 14 of Republic Act Number 1199, the Agricultural Tenancy Act. The case matters because it fixes the meaning of the phrase in both cases in that section, and settles whether a tenant who merely shifts from one crop-sharing arrangement to another must first serve a one-year notice on the landholder before he may sue.

Procedural History

The tenants filed their petition before the Court of Agrarian Relations. The landholder moved to dismiss, arguing that under the last part of section 14 the tenants could go to court only one agricultural year after serving notice of their intention to change upon the landholder, and that no such notice had been given. The tenants first replied that they had given notice, but later argued that notice was unnecessary because they were not asking for a change to the leasehold system. The agrarian court ruled for the landholder, reading the words in both cases to cover both a change from share tenancy to leasehold tenancy and a change from one crop-sharing arrangement to another, and held that service of one-year notice was a condition precedent to any cause of action. It accordingly dismissed the petition. The tenants appealed to the Supreme Court for revision.

Facts

Doroteo Onofre and eight other tenants worked land belonging to Ramon Cabral under a crop-sharing arrangement of forty-five percent to the tenant and fifty-five percent to the landholder. On the fourth of August, 1956, the nine tenants petitioned the Court of Agrarian Relations to compel the landholder to agree to an alteration of that arrangement to thirty seventy.

They rested the demand on section 14 of Republic Act Number 1199, which then gave the tenant the right to change the tenancy contract from share tenancy to leasehold tenancy and vice versa, and from one crop-sharing arrangement to another of the share tenancy.

The landholder opposed the petition and moved to dismiss, contending that the last part of the section required the tenants to wait one agricultural year after serving notice of their intention to change upon the landholder, and that no such notice had been served. The tenants first said they had given notice, then shifted ground and said notice was unnecessary because they sought no change to the leasehold system, only a change from one crop-sharing arrangement to another.

Issues

• Whether or not the words in both cases in the last sentence of section 14 of Republic Act Number 1199 refer to a change from share tenancy to leasehold tenancy and a change from one crop-sharing arrangement to another, as the agrarian court held.
• Whether or not tenants who seek only a change from one crop-sharing arrangement to another of the share tenancy must serve a one-year notice upon the landholder as a condition precedent to their cause of action.

Applicable Provisions

Section 14 of Republic Act Number 1199, as it stood at the time, provides:

SEC. 14. Change of System.—The tenant shall have the right to change the tenancy contract from one of share tenancy to the 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 may be exercised at the expiration of the period of the contract. In the absence of any written contract, the right may be exercised at the end of the agricultural year. In both cases the change to the leasehold system shall be effective one agricultural year after the tenant has served notice of his intention to change upon the landholder.

This is the provision the tenants invoked and the landholder used to defeat them, and its last sentence is the language the Court had to construe.

Section 14 of Republic Act Number 1199, as amended by Republic Act Number 2263, provides:

SEC. 14. Change of System.—The tenant shall have the right to change the tenancy contract from one of share tenancy to lease-hold 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 or from one tenancy system 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 exercise at least one month before the agricultural year when the change shall be effected.

The Court noted that this amended statute requires no previous one-year notice to the landholder, and that it directs the application of its provisions to cases pending in court at the time of its approval.

Ruling

On the first issue, the Court held that the agrarian court read the section wrongly. The words in both cases in the last sentence of section 14 refer to the two preceding sentences: first, a share contract in writing and duly registered, and second, a share contract not registered, or verbal, or implied. Both cases refer to share tenancy. The last part of the section must be interpreted to apply to instances where the tenants want a change from share tenancy to leasehold. That was not the situation before the Court, because there was no desire to adopt the leasehold system.

On the second issue, the Court held that there was no need of one-year notice, because the tenants' demand was not a change to the leasehold system. Notice as required by the last part of the section is not a condition precedent. The Court added that the section had recently been amended by Republic Act Number 2263, which requires no previous one-year notice to the landholder or landholder, and which directs the application of its provisions to cases like this one pending in court at the time of its approval.

Doctrine

Under section 14 of Republic Act Number 1199, the one-year notice of intention to change, which makes a change to the leasehold system effective one agricultural year after service upon the landholder, applies only where the tenant seeks a change from share tenancy to leasehold tenancy. The phrase in both cases refers to the two situations of a written and registered share contract and an unwritten share contract, both of which are share tenancy. A tenant who seeks only a change from one crop-sharing arrangement to another of the share tenancy need not serve that notice, and its absence is not a ground for dismissing his petition. The rule is tied to the statutory words themselves: the change to the leasehold system is what the one-year notice governs, and where no leasehold change is sought, no such notice is required.

Disposition

The Supreme Court found prejudicial error in the decision of the Court of Agrarian Relations, revoked it, and ordered the return of the record for further proceedings not inconsistent with its opinion, so the tenants prevailed.

Remember This

The line to memorize is that the one-year notice under section 14 of the Agricultural Tenancy Act is required only for a change to the leasehold system, not for a change from one crop-sharing arrangement to another. Examiners use this case to test close reading of statutory phrases like in both cases, and the rule that a condition precedent cannot be read into a statute that does not impose it on the situation at hand.