Vda. de Donato v. Court of Appeals
REITERATIONFacts
The Antecedents: Cresenciano Prado and Orlando de la Guison filed a complaint against Maria Luisa Vda. de Donato, alleging they were leasehold tenants of her riceland in Hda. Mercedes. They claimed she attempted to dispossess them without justifiable cause in 1979. Procedural History: The Court of Agrarian Relations found a tenancy relationship existed and ordered petitioner to maintain respondents in their landholdings. The Court of Appeals affirmed this decision. The Petition: Petitioner seeks a review of the Court of Appeals' decision, asserting that respondents were never her leasehold tenants.
Issue(s)
Whether or not respondents Cresenciano Prado and Orlando de la Guison are leasehold tenants of petitioner Maria Luisa Vda. de Donato. Whether the findings of the Court of Agrarian Relations, as affirmed by the Court of Appeals, are supported by substantial evidence.
Ruling
The decision of the Court of Appeals is AFFIRMED, with the modification that private respondents are considered leasehold tenants of petitioner. Costs are against petitioner.
Ratio Decidendi
On the issue of tenancy relationship and substantial evidence: The Supreme Court reiterated its consistent holding that findings of fact of the Court of Agrarian Relations will not be disturbed on appeal if supported by substantial evidence. Substantial evidence, defined as relevant evidence a reasonable mind might accept as adequate, does not require preponderant evidence. The Court found that both the Agrarian Court and the Court of Appeals had weighed the evidence of both parties and provided reasons for their conclusion. The evidence presented, including affidavits and certifications, supported the finding that Orlando de la Guison had been a tenant since 1971 and Cresenciano Prado since 1963, becoming a leasehold tenant in 1972. The Court noted that the essential requisites of a tenancy relationship (landholder and tenant, agricultural land, consent, purpose of agricultural production, and consideration) were concurrently satisfied. The Court also found that even without express consent, the petitioner impliedly recognized the respondents as tenants by allowing them to cultivate the land and receiving their share of the produce, establishing an implied contract of tenancy. On the issue of substantial evidence: The petitioner's contention that the land was solely for sugar cane and the respondents were mere laborers was belied by evidence of palay cultivation and the sharing of produce, thus alienating the Court from her claim. Therefore, the finding of a leasehold tenancy relationship was supported by substantial evidence.
Main Doctrine
The findings of the Court of Agrarian Relations, when supported by substantial evidence, will not be disturbed on appeal. Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.