Primary Holding

Section 14 of Republic Act No. 1199, which allows tenants to change their tenancy contract from share to leasehold, is constitutional and does not violate the constitutional prohibition against impairment of contracts.

Background

Geronimo B. Ramos, a tenant of Mateo de Ramas, sought to change their tenancy agreement from share to leasehold under Section 14 of Republic Act No. 1199. De Ramas refused, leading Ramos to file a petition with the Court of Agrarian Relations, which ruled in favor of Ramos. De Ramas appealed, challenging the constitutionality of Section 14.

Facts

• 1. Ramos was a tenant of de Ramas under a verbal share tenancy contract (70-30 sharing).
• 2. Ramos requested to change the contract to leasehold tenancy, but de Ramas refused.
• 3. Ramos filed a petition with the Court of Agrarian Relations, which approved the change.
• 4. De Ramas appealed, arguing that Section 14 of Republic Act No. 1199 was unconstitutional.

Arguments of the Petitioners

• 1. De Ramas argued that Section 14 of Republic Act No. 1199 was unconstitutional because it impaired the obligation of contracts by allowing tenants to unilaterally change the terms of the tenancy agreement.

Arguments of the Respondents

• 1. Ramos and the Court of Agrarian Relations argued that Section 14 was a valid exercise of police power aimed at promoting social justice and improving the economic condition of tenants, which is in line with the Constitution’s directive to protect agricultural laborers.

Issues

• 1. Whether Section 14 of Republic Act No. 1199, which allows tenants to change their tenancy contract from share to leasehold, is constitutional.

Ruling

• 1. The Supreme Court upheld the constitutionality of Section 14, ruling that it is a valid exercise of police power aimed at promoting social justice and improving the economic condition of tenants. The Court emphasized that the provision does not unreasonably impair contractual obligations and is justified by the need to protect tenants from exploitation and improve their economic standing.

Doctrines

• 1. Police Power: The state’s authority to enact laws promoting public welfare, even if they affect private contracts. Social Justice: The constitutional mandate to promote the well-being and economic security of all people, particularly the agricultural laborer.

Precedents Cited

• 1. Pineda, et al. vs. Pingui and CIR, G.R. No. L-5565, September 30, 1952: Upheld the constitutionality of Act No. 4054.
• 2. Tapang v. Court of Industrial Relations, 72 Phil. 79: Upheld the validity of laws protecting tenants from exploitation.

Statutory and Constitutional Provisions

• 1. Section 14 of Republic Act No. 1199: Allows tenants to change their tenancy contract from share to leasehold.
• 2. Article II, Section 5 of the Constitution: Promotion of social justice and economic security.
• 3. Article XIV, Section 6: Protection of agricultural laborers.