Del Rosario V de Los Santos

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 2

4. Del Rosario v De Los Santos of the share tenancy.

This was ruled upon already as constitutional in the case of De


GR NO. L-20589-90 Ramas v CAR.
21 March 1968 The purpose of this act is, according to Sec. 2, “to establish agricultural tenancy
By: Migs relations between landholders and tenants upon the principle of social justice; to
afford adequate protection to the rights of both tenants and landlords, to insure an
Topic: Basic Principles of Agrarian Reform equitable division of the produce and income derived from the land; to provide
Petitioners: Ernesto Del Rosario tenant-farmers with incentives to greater and more efficient agricultural production;
Respondents: Victorino De Los Santos and the Court of Agrarian Relations to bolster their economic position and to encourage their participation in the
Ponente: Fernando, J. development of peaceful, vigorous, and democratic rural communities.

RECIT-READY/SUMMARY: This is basically the history of the Agricultural Tenancy In history, land tenancy is a dark spot in the societies of Central Luzon; hence, a form
Ac and how it finds power through the police power of the State. of socialism became the remedy for the pitiful condition of the tenants. It was also
here that the tenants formed organizations as they rose in arms to save themselves
DOCTRINE: The police power is then sufficient to free the sad plight of Filipino from permanent thralldom. After 60 years, the tenant class then increased from 19%
tenants and agricultural workers. to 39%. This is what impelled the legislature to adopt the Act, particularly, Sec. 14
thereof.
FACTS:
 Two petitions were filed by Victorino and Tomas de los Santos before the As for the question of unconstitutionality, the Court in several cases simply explained
Court of Agrarian Relations (CAR) regarding their desire, as tenants of Del that “obligations of contracts must yield to a proper exercise of the police power of
Rosario, to use Sec. 14 of the Agricultural Tenancy Act and adopt the the state,” holding that the Act is therefore constitutional.
leasehold system provided, which will then change their status as tenants.
 Del Rosario, however, in his answer, challenged the validity of the cited Reinforced by the protection of labor and social justice provisions of the
provision; hence, a decision was rendered by CAR, which rejected Del Constitution, police power then justifies the enactment of this Act, which aids the
Rosario’s argument and declaring the relationship between him and de los economically under-privileged. Thus prior to the Act in question, several cases
Santos to be one of leasehold tenancy. already passed the validity of police power in favor of the economically under-
ISSUE: privileged such as Tapang v CIR and Ongsiako v Gamboa.
 W/N Sec. 14 of the Agricultural Tenancy Act is unconstitutional? (NO)
The police power is then sufficient to free the sad plight of Filipino tenants and
agricultural workers.
HELD/RATIO:
The framers of the Constitution, mindful of the then growing feeling of
As for “W/N the use of a tractor of a land-owner in addition to his carabao and farm
dissatisfaction with the ability of the government to cope with the poverty and
implements is a ground for disqualification of said land-owner to undertake the
misery of the vast majority of our people inserted the protection to labor and social
personal cultivation of his land and ejectment of his tenants pursuant to the Act,”
justice.
the Court simply explained that this issue is not deserving of further inquiry due to
the finding of the CAR that Del Rosario does not have the bona fide intention to
The legislation of the Agricultural Tenancy Act left no doubt about the validity of the
cultivate the landhilding in question.
remedy Congress intended to minimize the oppressive condition associated with
agricultural labor. As far as the social justice principle is concerned, President
Magsaysay explained it as, “he who has less in life should have more in law.”

Therefore, the Agricultural Tenancy Act of 1955 was passed, which vested in the
tenants “the right to change the tenancy contract from one of share tenancy to
leasehold tenancy and vice versa and from one-crop-sharing agreement to another

You might also like