ASSOC. OF SMALL LANDOWNERS vs. SEC.
OF AGRARIAN REFORM
G.R. No. 7874, July 14, 1989
Equal Protection
These are 3 cases consolidated questioning the constitutionality of the
Agrarian Reform Act. Article XIII on Social Justice and Human Rights includes
a call for the adoption by the State of an agrarian reform program. The State
shall, by law, undertake an agrarian reform program founded on the right of
farmers and regular farmworkers, who are landless, to own directly or
collectively the lands they till or, in the case of other farmworkers, to receive
a just share of the fruits thereof. RA 3844, Agricultural Land Reform Code, had
already been enacted by Congress on August 8, 1963. This was substantially
superseded almost a decade later by PD 27, which was promulgated on Oct
21, 1972, along with martial law, to provide for the compulsory acquisition of
private lands for distribution among tenant-farmers and to specify maximum
retention limits for landowners. On July 17, 1987, Cory issued EO 228,
declaring full land ownership in favor of the beneficiaries of PD 27 and
providing for the valuation of still unvalued lands covered by the decree as
well as the manner of their payment. This was followed on July 22, 1987 by
PP 131, instituting a comprehensive agrarian reform program (CARP), and EO
229, providing the mechanics for its implementation. Afterwhich is the
enactment of RA 6657, Comprehensive Agrarian Reform Law of 1988, which
Cory signed on June 10. This law, while considerably changing the earlier
mentioned enactments, nevertheless gives them suppletory effect insofar as
they are not inconsistent with its provisions.
In considering the rentals as advance payment on the land, the executive
order also deprives the petitioners of their property rights as protected by
due process. The equal protection clause is also violated because the order
places the burden of solving the agrarian problems on the owners only of
agricultural lands. No similar obligation is imposed on the owners of other
properties.
The petitioners maintain that in declaring the beneficiaries under PD 27 to be
the owners of the lands occupied by them, EO 228 ignored judicial
prerogatives and so violated due process. Worse, the measure would not
solve the agrarian problem because even the small farmers are deprived of
their lands and the retention rights guaranteed by the Constitution.
In his comment the Sol-Gen asserted that the alleged violation of the equal
protection clause, the sugar planters have failed to show that they belong to
a different class and should be differently treated. The Comment also
suggests the possibility of Congress first distributing public agricultural lands
and scheduling the expropriation of private agricultural lands later. From this
viewpoint, the petition for prohibition would be premature.
ISSUE: Whether or not there was a violation of the equal protection clause.
HELD: The SC ruled affirming the Sol-Gen. The argument of the small farmers
that they have been denied equal protection because of the absence of
retention limits has also become academic under Sec 6 of RA 6657.
Significantly, they too have not questioned the area of such limits. There is
also the complaint that they should not be made to share the burden of
agrarian reform, an objection also made by the sugar planters on the ground
that they belong to a particular class with particular interests of their own.
However, no evidence has been submitted to the Court that the requisites of
a valid classification have been violated.
Classification has been defined as the grouping of persons or things similar to
each other in certain particulars and different from each other in these same
particulars. To be valid, it must conform to the following requirements:
(1) it must be based on substantial distinctions;
(2) it must be germane to the purposes of the law;
(3) it must not be limited to existing conditions only; and
(4) it must apply equally to all the members of the class.
The Court finds that all these requisites have been met by the measures here
challenged as arbitrary and discriminatory.
Equal protection simply means that all persons or things similarly situated
must be treated alike both as to the rights conferred and the liabilities
imposed. The petitioners have not shown that they belong to a different class
and entitled to a different treatment. The argument that not only landowners
but also owners of other properties must be made to share the burden of
implementing land reform must be rejected. There is a substantial distinction
between these two classes of owners that is clearly visible except to those
who will not see. There is no need to elaborate on this matter. In any event,
the Congress is allowed a wide leeway in providing for a valid classification.
Its decision is accorded recognition and respect by the courts of justice
except only where its discretion is abused to the detriment of the Bill of
Rights.
