Rosario v. Santos
REITERATIONFacts
The Antecedents: Respondents Victorino de los Santos and Tomas de los Santos, tenants of petitioner Ernesto del Rosario, filed petitions before the Court of Agrarian Relations (CAR) on April 28, 1961, seeking to exercise their right under Section 14 of the Agricultural Tenancy Act of 1955 to change their tenancy contract from share tenancy to leasehold tenancy. Petitioner-landowner Ernesto del Rosario challenged the constitutionality of Section 14 in his answer filed on May 5, 1961. Procedural History: On October 26, 1962, the CAR rendered a joint decision, rejecting the claim of unconstitutionality of Section 14 and declaring the relationship between the respondent tenants and petitioner-landowner as one of leasehold tenancy effective as of the agricultural year 1961-1962. The Petition: Petitioner-landowner Ernesto del Rosario filed a petition for review of the CAR decision, again assailing the validity of Section 14 of the Agricultural Tenancy Act of 1955.
Issue(s)
Whether Section 14 of the Agricultural Tenancy Act of 1955 is constitutional. Whether the use of a tractor by a landowner constitutes a ground for disqualification from personal cultivation and ejectment of tenants.
Ruling
The Supreme Court affirmed the decision of the Court of Agrarian Relations, upholding the constitutionality of Section 14 of the Agricultural Tenancy Act of 1955 and finding no occasion to further consider the issue of ejectment due to the factual finding of the CAR regarding the landowner's lack of bona fide intention to cultivate the land personally.
Ratio Decidendi
On the constitutionality of Section 14 of the Agricultural Tenancy Act of 1955: The Court reiterated its consistent ruling that Section 14 is a valid exercise of the State's police power. This power is justified by the constitutional mandate to solve the age-old problem of tenancy and to promote social justice and protection to labor, ensuring that "He who has less in life should have more in law." The Court emphasized that tenancy legislation is a manifestation of deep concern for the welfare of agricultural workers, whose conditions have historically been marked by hardship. The provision allowing tenants to change their tenancy arrangement is a remedial measure designed to alleviate oppressive conditions and is not an unconstitutional impairment of the obligation of contracts or a transgression of the freedom of contract, as such rights must yield to the proper exercise of police power for the security of the State and the accomplishment of legitimate public interests. The Court cited previous decisions like De Ramas v. Court of Agrarian Relations and Ilusorio v. Court of Agrarian Relations which have consistently upheld the validity of this provision, finding no cogent reason to depart from established jurisprudence. The legislative act has a rational basis and is not unreasonable or oppressive, aligning with the constitutional intent to aid the economically underprivileged. On the issue of personal cultivation and ejectment: The Court declined to further inquire into whether the use of a tractor by the landowner disqualified him from personal cultivation and justified the ejectment of tenants. This was because the Court of Agrarian Relations had made an express finding of fact that the petitioner-landowner "does not have the bona fide intention to cultivate the landholding in question personally." As a finding of fact supported by substantial evidence, this determination is binding upon the Supreme Court on appeal and cannot be disturbed. Therefore, the issue of whether ejectment would lie became moot in light of this factual determination.
Main Doctrine
Section 14 of the Agricultural Tenancy Act of 1955, which empowers tenants to change their tenancy contract from share tenancy to leasehold tenancy and vice versa, is a valid exercise of police power, consistent with the constitutional provisions on social justice and protection to labor, and does not unconstitutionally impair the obligation of contracts or transgress the freedom of contract.