De Chavez vs. Zobel

Presidential Decree No. 27, as part of the law of the land under the 1973 Constitution, bars the ejectment of tenant farmers from the land they till, because it decrees their emancipation and transfers to them ownership of the land they cultivate, and any ruling permitting ejectment would set at naught an express mandate of the Constitution.

Enrique Zobel was the registered owner of Hacienda Bigaa in Calatagan, Batangas, a parcel of land with an aggregate area of more than five hundred hectares. The petitioners were his tenants tilling portions of the hacienda, with individual holdings ranging from approximately half a hectare to six hectares. The tenancy relationship and the respective areas cultivated by each tenant were undisputed and had been stipulated by the parties. Presidential Decree No. 27, issued on October 21, 1972, decreed the emancipation of all tenant farmers of private agricultural lands primarily devoted to rice and corn, transferring to them ownership of the land they till, and was upheld as part of the law of the land under the 1973 Constitution, which expressly provided that all decrees promulgated by the incumbent President shall be part of the law of the land.

Enrique Zobel was the registered owner of Hacienda Bigaa, a parcel of land located at Calatagan, Batangas, with an aggregate area of more than five hundred hectares. The petitioners — Zoila de Chavez, Bartolome Dimaala, Rufo Garcia, Paulino Esguerra, Fernando Veroya, Wilson Zapatero, Rufino Zapatero, Almario Alab, Roman Veroya, and Romana Vizconde — were his tenants tilling portions of the hacienda. Their individual holdings were small: de Chavez cultivated four lots aggregating about six hectares, while the others tilled from half a hectare to about three hectares each. The tenancy relationship and the respective areas cultivated by each tenant were undisputed, as the parties had stipulated these facts at the hearing on July 15, 1963.

Zobel sought to eject the petitioners, relying on Section 50 of Republic Act No. 1199, which would justify ejectment where the land is suited for mechanization. The petitioners vigorously objected, contending that the small areas they occupied were not suited for mechanization and alleging that Zobel's true intention was to utilize the land for pasture and for the raising of sorghum. The Court of Agrarian Relations dismissed the petition for ejectment, doubting Zobel's intent to mechanize and holding that mechanization during the rainy season was not practicable.

Zobel elevated the matter to the Court of Appeals, which reversed the Court of Agrarian Relations and granted the petition for ejectment. The petitioners then filed the present petitions for review with the Supreme Court. By the time the case reached the Supreme Court, Presidential Decree No. 27 had been issued on October 21, 1972, decreeing the emancipation of all tenant farmers and transferring to them ownership of the land they till. The 1971 Constitutional Convention voiced its overwhelming approval the very next month, and the decree became part of the law of the land under the 1973 Constitution.

• Unsuitability for Mechanization: Petitioners argued that the small areas they occupied were not suited for mechanization, and that Zobel's true intention was to utilize the land for pasture and for the raising of sorghum rather than for mechanized farming.
• Conclusiveness of CAR Findings: Petitioners stressed the basic doctrine that the findings of fact of the Court of Agrarian Relations, supported by substantial evidence, are well-nigh conclusive on an appellate tribunal.

• Statutory Ground for Ejectment: Respondent Zobel relied on the provision of Republic Act No. 1199, specifically Section 50, which would justify ejectment of tenants where the land is suited for mechanization.

• Applicability of Presidential Decree No. 27: Whether Presidential Decree No. 27, decreeing the emancipation of tenants and transferring to them ownership of the land they till, bars the ejectment of petitioners from their tenanted holdings.
• Conclusiveness of CAR Findings: Whether the findings of fact of the Court of Agrarian Relations, supported by substantial evidence, are conclusive on an appellate tribunal.

• Applicability of Presidential Decree No. 27: Yes. Ejectment of the petitioners is barred, Presidential Decree No. 27 having decreed the emancipation of tenants and transferred to them ownership of the land they till, and being part of the law of the land under the 1973 Constitution.
• Conclusiveness of CAR Findings: Acknowledged as a valid doctrine but rendered moot by the controlling constitutional provision. The Court noted that the submission is supported by a host of decisions dating back to 1958, but found discussion of the assigned errors fruitless given the dispositive effect of PD 27.

• Applicability of Presidential Decree No. 27: Presidential Decree No. 27 was issued in October 1972 and decreed the emancipation of all tenant farmers from the bondage of the soil, transferring to them ownership of the land they till. The 1971 Constitutional Convention voiced its overwhelming approval the very next month. Under Article XVII, Section 3, paragraph 2 of the 1973 Constitution, all decrees promulgated by the incumbent President shall be part of the law of the land and shall remain valid, legal, binding, and effective. Article XIV, Section 12 of the same Constitution ordains that the State shall formulate and implement an agrarian reform program aimed at emancipating the tenant from the bondage of the soil. To permit the ejectment of petitioners from their small landholdings would set at naught this express constitutional mandate and perpetuate the misery that tenancy had spawned, as well as the grave social problems thereby created. The cardinal postulate of constitutionalism — the supremacy of the fundamental law — requires obedience once the Constitution has spoken. There can be no justification for any other decision, whether predicated on a juridical norm or on the traditional role of the judiciary of implementing and not thwarting fundamental policy goals.

• Conclusiveness of CAR Findings: The petitioners' submission that the findings of fact of the Court of Agrarian Relations, supported by substantial evidence, are well-nigh conclusive on an appellate tribunal was acknowledged as supported by a host of decisions dating back to 1958, including Atayde vs. De Guzman and De Miranda vs. Reyes. However, with the disposition of the petitions clearly indicated by the controlling constitutional provisions, a discussion of the errors assigned by petitioners was deemed fruitless, as the applicability of PD 27 was unavoidable and dispositive.

• Constitutional Supremacy in Agrarian Reform — The cardinal postulate of constitutionalism, the supremacy of the fundamental law, requires that once the Constitution has spoken, obedience is unavoidable. In this case, the 1973 Constitution expressly adopted Presidential Decree No. 27 as part of the law of the land and mandated an agrarian reform program aimed at emancipating the tenant from the bondage of the soil. The Court applied this doctrine to bar the ejectment of tenant farmers, holding that any other approach would run the risk of setting at naught the basic aspiration to do away with all remnants of a feudalistic order.

• Conclusiveness of CAR Findings of Fact — The findings of fact of the Court of Agrarian Relations, when supported by substantial evidence, are well-nigh conclusive on an appellate tribunal. This doctrine, traceable to 1958 decisions including Atayde vs. De Guzman and De Miranda vs. Reyes, was acknowledged by the Court as valid but rendered moot by the controlling effect of Presidential Decree No. 27.

• "Ejectment therefore of petitioners is simply out of the question. That would be to set at naught an express mandate of the Constitution. Once it has spoken, our duty is clear; obedience is unavoidable." — This passage states the ratio decidendi: that the constitutional adoption of PD 27 as part of the law of the land precludes judicial approval of tenant ejectment, grounding the ruling in the supremacy of the fundamental law.

• "To deprive petitioners of the small landholdings in the face of a presidential decree considered ratified by the new Constitution and precisely in accordance with its avowed objective could indeed be contributory to perpetuating the misery that tenancy had spawned in the past as well as the grave social problems thereby created." — This passage articulates the social justice rationale underlying the ruling, connecting the constitutional mandate to the historical problem of tenancy and the need for a radical solution.

• "There can be no justification for any other decision then whether predicated on a juridical norm or on the traditional role assigned to the judiciary of implementing and not thwarting fundamental policy goals." — This passage defines the Court's view of the judicial role in relation to fundamental policy goals: the judiciary must implement, not thwart, constitutional mandates.

• Guido vs. Rural Progress Administration, 84 Phil. 847 (1949) — Cited for Justice Tuason's reference to Jose Rizal's concern over the tenancy problem, providing historical context for the gravity of the agrarian issue.
• De Ramas vs. Court of Agrarian Relations, L-19555, May 29, 1964, 11 SCRA 171 — Cited for Justice Labrador's vivid description of the history of land tenancy in Central Luzon and the social unrest it spawned, supplying the social backdrop for the emancipation decree.
• Atayde vs. De Guzman, 103 Phil. 187 (1958) and De Miranda vs. Reyes, 103 Phil. 207 (1958) — Leading cases establishing the doctrine that findings of fact of the Court of Agrarian Relations, supported by substantial evidence, are conclusive on appellate tribunals; acknowledged but rendered moot by the controlling constitutional provision.

• Presidential Decree No. 27 (October 21, 1972) — Decreed the emancipation of all tenant farmers from the bondage of the soil, transferring to them ownership of the land they till. Applied as the controlling legal basis barring the ejectment of petitioners, the decree being part of the law of the land under the 1973 Constitution.
• Article XVII, Section 3, paragraph 2, 1973 Constitution — Provided that all proclamations, orders, decrees, instructions, and acts promulgated by the incumbent President shall be part of the law of the land and shall remain valid, legal, binding, and effective. Applied to establish that PD 27 formed part of the law of the land.
• Article XIV, Section 12, 1973 Constitution — Ordained that the State shall formulate and implement an agrarian reform program aimed at emancipating the tenant from the bondage of the soil. Applied as the constitutional policy underlying the ruling.
• Section 50, Republic Act No. 1199 (1954) — Permitted ejectment of tenants where the land is suited for mechanization. Relied upon by respondent Zobel as the statutory ground for ejectment, but rendered inoperative against petitioners by the superior mandate of PD 27.

Zaldivar (Chairman) and Aquino, JJ., concurred in the majority opinion.

Barredo, J., concurred separately, joined by Antonio, J. His concurrence addressed solely the characterization of the 1973 Constitution: he maintained that it is a new constitution, not a "revised" one, citing Article XVII, Section 16, which provides that the new Constitution shall supersede the 1935 Constitution and all amendments thereto. He argued that the replacement is integral and that the innovations introduced by the new charter are so substantial and far-reaching that only blind loyalty to the old could make anyone insist it is merely an amendment. He further noted his oath to uphold and defend the "bagong Saligang-Batas" (new Constitution).