Federation of Free Farmers vs. CA (GR No. L-41161. Sept.
10, 1981) members of or represented by the Federation of Free Farmers, one of herein
Topic: Graphical illustration
Petitioners: Federation of Free Farmers, Melquiades Betios,
Cresenciano Fernandez, Sancho Perez, Agaton Posa
Respondents: Hon. Court of Appeals, Victorias Milling Company, Inc.,
Victorias Mill District Planters’ Association, Inc.,
All sugarcane planters of sugarcane plantations
situated in the Victorias Milling District, who have at
one time or another, since June 22, 1952, milled their
sugarcane in the mill of Victorias Milling Company, Inc.
Ponente: Barredo, J:
Sec. 1 provides that “in the ​absence of written milling agreements between the
majority of ​planters and millers of sugarcane in any milling district in the
Philippines, the unrefined sugar produced in that district from the milling by the
sugar central of the sugarcane of any sugarcane planter or plantation owner, as well
as all by-products and derivatives thereof, shall be ​divided ​between them” in the
proportion​ therein specified” (pp. 381 - 382).
Sec. 9 provides that “the ​proceeds of any increase in participation granted the
planters under this Act and above their present share shall be ​divided between the
planter and his laborer in the plantation” in the proportion of 60% for the laborer
and ​40%​ for the planter”.
Issue:
1. Does RA 809 (Sugar Act of 1952) apply even if a written milling agreement
exists between the planter and the central stipulating a sharing proportion
different from those in Sec. 1, provided that any increase of participation
granted the planter will be divided between the planter and his laborer in the
proportion of 40% and 60 % respectively, pursuant to Sec. 9?
2. What is the legislative intent which should be given effect?
Facts:
The appellate court held that notwithstanding the provisions of
Section 9, in relation to Section 1 of the Sugar Act of 1952, Republic Act 809,
providing that of any increase in the share of the proceeds of milled
sugarcane and derivatives obtained by the planters from the centrals in any
sugar milling district in the Philippines, 60% of said increase shall correspond
to and should be paid by the planters to their respective laborers, the
laborers of the planters affiliated to the Victorias Milling District who are
petitioners, have not been fully paid their share thus provided by law,
corresponding to crop years 1955 to 1974, in spite of clear evidence in the
record showing that the increase of 4% in the share of the Planters, Victorias
Milling District, corresponding to all the years since the enforcement of the
aforementioned Act had already been paid by petitioner Victorias Milling Co.,
Inc. to said planters. The Court of Appeals further found that even the shares
of the laborers corresponding to crop years 1952-1955, when by operation of
the Act, the increase was 10%, had not been paid. The appellate court
rendered judgment holding the planters of the district and Victorias Milling
Co., Inc. jointly and severally liable to the said laborers for all said alleged
unpaid amount
Ruling:
1. In ​Talisay-Silay​, the Court ruled that the existence of milling agreements does
not necessarily render RA 809 inapplicable or inoperative. The ​act remains
applicable and operative in all cases where the milling agreements provide any
increase in planter participation.
There is nothing in the law that excludes the right of the planters and millers to
enter into new contracts wherein they could provide for a ratio of sharing
different from that stipulated in Sec. 1 ​provided that ​any increase of planters’
share in the proceeds, 60% thereof must be paid to their laborers (Sec. 9
applies here).
The prerequisite of absence of milling agreements for the application of Sec. 1
does not refer exclusively to the existing contracts expired before the approval
of RA 809, but even to future failure of centrals and planters to enter into
written milling contracts (Sec. 1 applies here).
2. The purpose of the legislature is to compel the continuous production of sugar
and to grant the planters’ laborers a share in the increased participation of the
planters in the sugar produce. If a literal interpretation of Secs. 1 and 9 is to be
given effect, such would defeat the purpose of the Act. Simply put, the purpose
of the Act is to give the laborers a share for as long as sugar is produced and
the planters receive an increased participation. The legislative intent,
therefore, is to ​make the Act operative regardless of whether there exists a
milling agreement between the central and the sugar planters​.
Notes: Reason for enactment of RA 809
1. An examination of RA 809 and the sugar industry as a whole shows that
centrals practically dominated the economic fate of planters and the laborers
of the latter, while the planters’ laborer had always been at the losing end in
terms of wages and benefits. The planter claims that he is not able to
adequately compensate his laborers because of the millers not giving him his
rightful share in the sugar produce milled by the central.
2. During the 1950s, when the long-term contracts between the millers and
planters had expired or were about to expire, and negotiations for another
were in progress, the planters would stage strikes and threatened not to plant
cane unless they were given a bigger share in the sugar industry as a whole.
3. To solve the problem, Congress enacted RA 809 (Sugar Act 1952). Government
was to take over the planting and milling in the event that the planters and
millers refused to do their respective roles in the production of sugar.
Association vs. Talisay (GR No. L-19937, February 19, 1989)
Topic: Graphical Illustration
Petitioners: Asociacion de Agricultures de Talisay-Silay, Inc., et al
[PLANTERS]
Respondents: Talisay-Silay Milling Co., Inc., et al [CENTRAL]
Ponente: Barredo, ​J.
Issue:
Is Republic Act No. 809 constitutional?
-​ ​Violates equal protection clause
- The constitutional guarantee on the freedom of contracts and
non-impairment clause of the Constitution
Facts:
In the issuance of Republic Act No. 809 or the Sugar Act of 1952, “An Act to
Regulate the Relations Among Persons Engaged in the Sugar Industry,” which
regulates the relations among persons engaged in the sugar industry - the unrefined
sugar produced in that district from the milling by any sugar central of the sugar
cane of any sugarcane planter or planter owner, as well as all byproducts and
derivatives thereof, shall be divided between them depending on the maximum
actual production. The statute observes whether the milling companies have milling
contracts between their laborers or employees. In this case, the Asociation de
Agricultores de Talisay-Silay, Inc. or the PLANTERS and Talisay-Silay Milling Co., Inc.
or the CENTRAL had no written milling contracts between them in the crop year
1952-1953 and every year thereafter. Also, the statute sought to increase sharing
participation or proportion between the PLANTERS and the CENTRAL. The higher
the rate of publication, the bigger the percentage given to the PLANTERS. Although,
the CENTRAL states that they have entered into contracts with eight (8) planters in
1954 which prays to be declared applicable to them starting the crop year
1954-1955. Also, since the crop year 1920-1921, the CENTRAL “bound itself to give
all planters having contracts with it the highest rate of participation it would ever
give to any planter” (a concept of the most favored planter).
The Association de Agricultores Talisay-Silay and six sugarcane planters
(PLANTERS) filed a petition to the Secretary of Labor, praying that the latter declare
the applicability of the RA 809 to the Talisay-Silay Mill District (CENTRAL) for every
crop year starting from 1952-1962.
The CENTRAL questioned the constitutionality of the RA 809 in their favor
because of the fact that the PLANTERS have the initial milling contracts which they