Tolentino vs. Alzate

Republic Act No. 1199’s requirement that a landlord file notice with the court, inform the tenant in writing, and secure a certification from the Secretary of Agriculture and Natural Resources at least one year but not more than two years before petitioning to dispossess a tenant for mechanization is substantive and cannot be applied retroactively to a petition filed before the statute’s approval. A statute merely regulating court procedure may be given retroactive effect to pending actions, but a prerequisite that must be complied with before a case can be brought to court is substantive and cannot be given retroactive effect unless clearly expressed in the law.

Antonio O. Alzate was the manager of an hacienda located in Nampicuan and Guimba, Nueva Ecija, where nineteen tenants worked a portion covering more than 67 hectares. Republic Act No. 1199, approved on August 30, 1954, governed the relations of landlords and tenants of agricultural lands and recognized the landlord’s desire to cultivate the land through farm machinery and implements as a cause for dispossession, subject to stated requirements. The dispute required the Court to determine the temporal reach of that statute over a petition already filed with the Court of Industrial Relations.

Antonio O. Alzate, as manager of an hacienda located in the municipalities of Nampicuan and Guimba, Nueva Ecija, filed a petition with the Court of Industrial Relations on August 12, 1954. He asked for permission to lay off nineteen tenants who were working on a portion covering an area of 67+ hectares to enable the hacienda’s owner to introduce a mechanization program that would increase production at lesser cost beginning with the agricultural year 1955-1956.

The tenants answered the petition. They denied that the portion sought to be mechanized was suitable to mechanized farming and alleged that the real purpose of the petition was to eject them and create an atmosphere of fear among them because they had previously filed a claim against the hacienda seeking certain improvements in their tenancy relation. Issues were joined and the case was set for hearing.

In the meantime, Republic Act No. 1199 was approved on August 30, 1954. It governed the relations of landlords and tenants of agricultural lands and provided that mechanized farming was one of the causes for dispossession of a tenant. Under Section 50, paragraph (a), the landlord was required, at least one year but not more than two years prior to the date of the petition to dispossess the tenant, to file notice with the court and to inform the tenant in writing, in a language or dialect known to the latter, of the intention to cultivate the land personally or through mechanical implements, together with a certification from the Secretary of Agriculture and Natural Resources that the land was suited for mechanization.

In view of the approval of Republic Act No. 1199, the tenants moved to dismiss the case on the ground of lack of jurisdiction, arguing that the procedure required as a prerequisite for mechanized farming had not been complied with. The motion was denied, as were two motions for reconsideration filed by the tenants. The tenants then interposed the present petition for review.

• Lack of Jurisdiction: Petitioners maintained that the Court of Industrial Relations had no jurisdiction to proceed with the hearing because the landlord had not complied with the prerequisite procedure in Republic Act No. 1199 for mechanized farming before filing the petition for mechanization.
• Noncompliance with Section 50(a): Petitioners contended that under Republic Act No. 1199, the landlord was required to file notice with the court, inform the tenant in writing, and secure a certification from the Secretary of Agriculture and Natural Resources at least one year but not more than two years prior to the petition to dispossess, and that no such compliance had been shown.
• Denial of Day in Court: Petitioners claimed that the industrial court acted upon their motion for reconsideration without hearing, thereby depriving them of their day in court.
• Improper Purpose and Unsuitability: In their answer, petitioners denied that the portion sought to be mechanized was suitable to mechanized farming and alleged that the purpose was merely to eject them and create fear because they had previously filed a claim for improvements in their tenancy relation.

• Retroactive Application of Republic Act No. 1199: Whether Republic Act No. 1199, particularly the requirement in Section 50(a) that the landlord file notice and secure certification at least one year but not more than two years before petitioning to dispossess a tenant for mechanization, applies retroactively to a petition filed before the statute’s approval, such that noncompliance deprived the Court of Industrial Relations of jurisdiction.
• Nature of the Mechanization Requirement: Whether the requirement is merely procedural and thus may apply to pending actions, or substantive and thus cannot be given retroactive effect absent clear legislative intent.
• Denial of Day in Court: Whether the Court of Industrial Relations deprived petitioners of their day in court by resolving their motion for reconsideration without a hearing.

• Retroactive Application of Republic Act No. 1199: No. The petition was filed on August 12, 1954, before Republic Act No. 1199 was approved on August 30, 1954; under Article 4 of the New Civil Code, laws have no retroactive effect unless the contrary is provided, and the statute contains no such provision.
• Nature of the Mechanization Requirement: Substantive. The requirement must be complied with before the case could be brought to court, not merely a matter of court procedure; it cannot be applied retroactively unless clearly expressed.
• Denial of Day in Court: No. Under the rules of the Court of Industrial Relations, a motion is deemed submitted for resolution after an answer, unless the court considers a hearing necessary; the matter is addressed to the court’s discretion.

• Retroactive Application of Republic Act No. 1199: The Court began from the rule that “Laws shall have no retroactive effect, unless the contrary is provided” under Article 4 of the New Civil Code, and that a statute operates prospectively unless legislative intent to the contrary is made manifest by express terms or necessary implication. Republic Act No. 1199 was approved on August 30, 1954, while Alzate’s petition was filed on August 12, 1954. Nothing in the statute makes its provisions retroactive, including the provision on mechanized farming. Consequently, the prerequisite did not apply to the already-filed petition, and the Court of Industrial Relations did not lose jurisdiction for noncompliance.
• Nature of the Mechanization Requirement: The tenants invoked the possible exception that statutes merely regulating court procedure may be given retroactive effect to pending actions. The Court rejected this because Section 50(a) does not merely regulate procedure; it requires the landlord, at least one year but not more than two years prior to the date of the petition to dispossess, to file notice with the court, inform the tenant in writing, and secure certification from the Secretary of Agriculture and Natural Resources that the land is suited for mechanization. This is a condition that must be complied with before the case could be brought to court. It is substantive and cannot be retroactive unless clearly expressed. Since it was not clearly expressed, it did not govern the petition filed before the law.
• Denial of Day in Court: The Court noted that under the rules of the Court of Industrial Relations, a motion is deemed submitted for resolution after an answer, except when the court itself considers it necessary to hear the parties. The resolution of the motion for reconsideration without hearing was therefore within the court’s discretion and did not deprive petitioners of their day in court.

• Non-retroactivity of statutes — Article 4 of the New Civil Code provides that laws shall have no retroactive effect unless the contrary is provided. A statute operates prospectively and never retroactively unless legislative intent to the contrary is made manifest by express terms or necessary implication. The Court applied this rule to hold that Republic Act No. 1199 did not apply to a petition filed before its approval.
• Substantive versus procedural statutes — A statute merely regulating court procedure may be applied retroactively to pending actions. However, a requirement that must be complied with before a case can be brought to court is substantive and cannot be given retroactive effect unless clearly expressed. The Court applied this distinction to Section 50(a) of Republic Act No. 1199, holding it substantive.
• Jurisdictional prerequisite — Compliance with Republic Act No. 1199’s notice and certification requirements is necessary for the Court of Industrial Relations to act on a mechanization dispossession petition. Because the petition predated the law, however, noncompliance did not divest the court of jurisdiction.
• Discretion to resolve motions without hearing — Under the rules of the Court of Industrial Relations, a motion is deemed submitted for resolution after an answer, unless the court considers a hearing necessary. The Court applied this rule to reject the claim of denial of due process.

• "It is a well known rule that 'Laws shall have no retroactive effect, unless the contrary is provided' (Article 4, new Civil Code)." — States the general non-retroactivity rule applied to Republic Act No. 1199.
• "A statute operates prospectively and never retroactively, unless the legislative intnet to the contrry is made manifest either by the express terms of the statute or by necessary implication" — Canonical formulation from Segovia vs. Noel, cited to reject retroactive application of the statute.
• "but the provision under consideration does not merely partake of a court procedure but refers to a requirement which must be complied with before the case could be brought to court." — Distinguishes procedural statutes from substantive prerequisites.
• "Such provision is clearly substantive in nature and cannot be given retroactive effect unless so clearly expressed in the law." — Holds that Section 50(a) of Republic Act No. 1199 is substantive and not retroactive.

• Segovia vs. Noel, 47 Phi., 543 — Cited for the rule that a statute operates prospectively and never retroactively unless legislative intent to the contrary is made manifest by express terms or necessary implication.
• People vs. Sumilang, 44 Off. Gaz. No. 3, p. 881 — Cited for the proposition that a statute merely regulating court procedure may be given retroactive effect to pending actions; distinguished because the Republic Act No. 1199 requirement is substantive, not merely procedural.

• Article 4, New Civil Code — Laws shall have no retroactive effect unless the contrary is provided. Applied to hold that Republic Act No. 1199 was not retroactive.
• Section 50, paragraph (a), Republic Act No. 1199 — Requires the landlord, at least one year but not more than two years prior to the petition to dispossess a tenant, to file notice with the court, inform the tenant in writing in a known language or dialect of the intention to cultivate personally or through mechanical implements, and secure certification from the Secretary of Agriculture and Natural Resources that the land is suited for mechanization. Held substantive and not applicable retroactively.
• Rules of the Court of Industrial Relations — A motion is deemed submitted for resolution after an answer, unless the court considers a hearing necessary. Applied to reject the due process claim.

Paras, C.J.; Bengzon; Padilla; Montemayor; Reyes, A.; Jugo; Labrador; Concepcion; Reyes, J.B.L.; and Endencia, JJ., concur.