People v. Adillo
REITERATIONFacts
The Antecedents: Elias Adillo, a share-tenant of Saturnino L. Rebong, was charged with violation of Section 39 of the Agricultural Tenancy Act (Republic Act No. 1199) for allegedly reaping and threshing a portion of palay without the knowledge and consent of the landholder and before a date was fixed for the harvest. The offense was alleged to have occurred on or about October 3, 1960. Procedural History: The defendant-appellee moved to quash the information, arguing that the Agricultural Tenancy Act had been repealed by the Agricultural Land Reform Code (Republic Act No. 3844), thereby extinguishing his criminal liability. The Court of First Instance of Laguna granted the motion and dismissed the case. The Petition: The State appealed the dismissal order, questioning whether the penal liability for pre-reaping or pre-threshing under the Agricultural Tenancy Act was obliterated by subsequent agrarian laws.
Issue(s)
Whether the penal liability of a share-tenant for pre-reaping or pre-threshing under the Agricultural Tenancy Act (Republic Act No. 1199) has been obliterated by the Agricultural Land Reform Code (Republic Act No. 3844) and subsequent agrarian laws. Whether the omission of Section 39 of the Agricultural Tenancy Act in subsequent agrarian laws constitutes an implied repeal, thereby depriving courts of jurisdiction.
Ruling
The Court affirmed the order of dismissal of the information against the defendant-appellee. The penal liability for pre-reaping and pre-threshing under the Agricultural Tenancy Act of 1954 has lost its operative force and effect due to subsequent agrarian reforms.
Ratio Decidendi
On the issue of obliteration of penal liability by subsequent agrarian laws: The Court held that the penal liability for pre-reaping or pre-threshing under Section 39 of the Agricultural Tenancy Act (Republic Act No. 1199) has been obliterated by the Agricultural Land Reform Code (Republic Act No. 3844, as amended by Republic Act No. 6389) and subsequent agrarian laws and decrees. The Agricultural Land Reform Code declared agricultural share tenancy contrary to public policy and abolished it, although existing contracts were allowed to continue under certain conditions. The subsequent issuance of Presidential Decree No. 2, proclaiming the entire country as a land reform area, unqualifiedly abolished the sharehold system. The omission of Section 39 of the Agricultural Tenancy Act in the new Code operates as an implied repeal of said provision, as it is a well-settled principle of statutory construction that when an act purports to set out in full all that it intends to contain, it operates as a repeal of anything omitted which was contained in the old act and not included in the amendatory act. Therefore, the injunction against pre-reaping and pre-threshing under the Agricultural Tenancy Act of 1954 no longer has operative force and effect, and the penal sanction therein is subdued. On the issue of implied repeal and jurisdiction: The Court stated that the omission of Section 39 of the Agricultural Tenancy Act of 1954 in the subsequent agrarian laws and decrees, which failed to penalize the acts of pre-reaping and pre-threshing, carries with it the deprivation of the courts of jurisdiction to try, convict, and sentence persons charged with its violations. This is because the offense defined and penalized under Section 39 no longer exists. Citing People vs. Tamayo and People vs. Pastor, the Court emphasized that it would be illogical to prosecute or sentence a defendant for an offense that no longer exists. The whole failure of the laws and decrees subsequent to the Agricultural Tenancy Act of 1954 to penalize these acts signifies the loss of operative force and effect of the prohibition and its penal sanction.
Main Doctrine
The penal liability for pre-reaping or pre-threshing under Section 39 of the Agricultural Tenancy Act (Republic Act No. 1199) was obliterated by the Agricultural Land Reform Code (Republic Act No. 3844, as amended) and subsequent agrarian laws and decrees, as the said provision was not carried over and its omission operates as an implied repeal, thus depriving courts of jurisdiction to try, convict, and sentence persons charged with its violation.