Guerrero v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the classification of a worker on a coconut landholding. The plaintiff-appellant claimed to be a tenant with a sharing agreement of 1/3-2/3 in favor of the defendant-appellee, performing all stages of coconut cultivation and residing on the land. The defendant-appellee, however, contended that the plaintiff-appellant was a hired farm laborer paid a wage of P17.00 per thousand coconuts. 2. Procedural History: The Court of Appeals, in a decision promulgated on October 10, 1974, ruled in favor of the plaintiff-appellant, declaring him a tenant and ordering the defendant-appellee to maintain his possession, reimburse him for his share of coconuts, and render an accounting of future harvests. The petitioner sought reconsideration, arguing the decision was not supported by evidence. This motion was denied by the Court of Appeals in a resolution promulgated on November 29, 1974, which reiterated its findings that the plaintiff-appellant was a tenant based on the nature of his work and his investment in housing. 3. The Petition: The petitioner elevated the case to the Supreme Court via a Petition for certiorari under Rule 45 of the Rules of Court, primarily arguing that the Court of Appeals' decision was not supported by evidence, which they contended presented a question of law. The Supreme Court, however, found the petition devoid of merit, agreeing with the private respondent that the issue of whether the decision was supported by evidence constituted a question of fact, which is generally not reviewable by the Supreme Court under Rule 45, absent specific exceptions not present in this case. The Court distinguished the present case from cited precedents, emphasizing that the Court of Appeals made its own factual findings based on conflicting evidence, unlike cases involving undisputed facts or conclusions of executive officers.
Issue(s)
Whether the Court of Appeals erred in finding the plaintiff-appellant to be a tenant rather than a hired farm laborer. Whether the findings of fact of the Court of Appeals are reviewable by the Supreme Court in a Petition for certiorari under Rule 45. Whether the questions raised in the Petition are questions of law as required under Rule 45, Section 2. Whether the Court of Appeals so departed from accepted judicial procedure as to warrant Supreme Court intervention under Section 4, Rule 45.
Ruling
The Petition under Rule 45 is DENIED for lack of merit. The findings and conclusions of the Court of Appeals upholding the existence of a tenancy relationship are not disturbed. No pronouncement as to costs.
Ratio Decidendi
On Whether the Court of Appeals erred in finding plaintiff-appellant a tenant: The Supreme Court held that the Court of Appeals made its own findings of fact apart from the agrarian court and based its conclusions on those factual findings. The Court reiterated that credibility of witnesses and weighing of conflicting evidence are matters within the exclusive authority of the Court of Appeals, a principle stated in Santa Ana, Jr. v. Hernandez. The Court emphasized that it will not re-examine the evidence in a Rule 45 petition except in unusual circumstances, such as when findings are totally devoid of support or so glaringly erroneous as to constitute serious abuse of discretion. The Supreme Court found that the Court of Appeals' findings regarding the claimant's performance of agricultural tasks, his residence on the land, payment for construction of housing, and historical tenancy ties were supported by the record and rationally led to the conclusion of tenancy. Accordingly, the Court concluded there was no basis to overturn the Court of Appeals' factual determination that the plaintiff-appellant was a tenant entitled to security of tenure. On Whether the Court of Appeals' findings of fact are reviewable under Rule 45: The Court explained that Rule 45 permits review of Court of Appeals decisions only on questions of law. The Court quoted Santa Ana, Jr. v. Hernandez to the effect that credibility and weighing of evidence are within the exclusive authority of the Court of Appeals and are not ordinarily reviewable by the Supreme Court. The Court further stated that it would set aside findings of fact only when they are totally devoid of support in the record or so glaringly erroneous as to constitute serious abuse of discretion. Applying that standard, the Court found the Court of Appeals' factual findings were neither unsupported nor glaringly erroneous, but grounded on evidence and reasonable inferences; therefore, they must stand. On Whether the issues raised are questions of law within the scope of Rule 45: The Supreme Court analyzed the rule distinguishing questions of law from questions of fact, citing Ramos v. Pepsi-Cola Bottling Co., explaining that a question of law exists when the doubt concerns what the law is on a given state of facts and does not call for examination of the probative value of evidence. The Court found that the petition's principal contention—that the Court of Appeals' decision was not supported by evidence—necessarily required reweighing evidence and assessing credibility, which are factual inquiries. Since the petition raised primarily factual disputes rather than pure legal questions, it did not present the limited questions of law reviewable under Rule 45. On Whether a departure from accepted judicial procedure justified intervention under Section 4, Rule 45: The Court reviewed the grounds under Section 4, Rule 45 that permit Supreme Court review, such as departure from accepted procedure or decisions on questions of substance not previously determined by the Supreme Court. The Court did not find that the Court of Appeals had committed any such departure or decision on a novel question of law. The Court therefore exercised its discretion to deny the petition and left intact the Court of Appeals' disposition.
Main Doctrine
Under a Petition for certiorari under Rule 45 of the Rules of Court, the Supreme Court will not re-examine findings of fact of the Court of Appeals unless such findings are totally devoid of support in the record or so glaringly erroneous as to constitute serious abuse of discretion; questions of law alone are reviewable.