Espadera v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns the tenancy rights over a parcel of land. Anulina Vda. de Bogacki purchased a property in 1954, using P800.00 of her minor daughter Emma's funds, for which Anulina was the appointed guardian. Anulina subsequently instituted Ciriaca Gepayo as a tenant on the land. Later, Anulina mortgaged the property and executed a leasehold contract with Ciriaca and her husband, Ambrocio Gepayo. After Anulina was required to reconvey the property to Emma, Emma, who had since married Antonio Chu, sold the property to the petitioners, Dioscord Espadera and Liceria Espadera. The petitioners then fenced the property, preventing the private respondents from accessing it. Procedural History: The private respondents, Ciriaca and Ambrocio Gepayo, filed an action for reinstatement and damages against the petitioners in the Regional Trial Court (RTC) of Iloilo City, asserting their status as agricultural tenants since 1954. The RTC dismissed their complaint for lack of cause of action. Upon appeal to the Court of Appeals (CA), the CA reversed and set aside the RTC's decision, declaring the Gepayos as tenants/lessees entitled to reinstatement and ordering the Espaderas to pay damages and litigation expenses. The Petition: The petitioners, Dioscord and Liceria Espadera, filed this petition for review of the CA's decision. They contend that the property over which the private respondents claim tenancy is different from the property they purchased. Specifically, they argue that the land sold to Emma had an area of 3,887 square meters, while the land Anulina purchased from Pedro Ledesma had a total area of 7,643 square meters. The Supreme Court noted that the identity of the property was not raised in the lower courts and is being raised for the first time on appeal, which is generally not permitted. The Court found the CA's factual findings regarding the tenancy to be conclusive and binding.
Issue(s)
Whether the Court of Appeals erred in reversing the decision of the Regional Trial Court. Whether the issue of the identity of the property can be raised for the first time on appeal.
Ruling
The petition is denied for lack of merit. The Court affirmed the decision of the Court of Appeals, declaring the private respondents as tenants/lessees of the land in question, entitled to reinstatement.
Ratio Decidendi
On the issue of the Court of Appeals' reversal of the RTC decision: The findings of fact made by the respondent Court of Appeals to the effect that the private respondents are tenants of the petitioners are conclusive and binding on the petitioners. Factual issues cannot be raised in a petition for review before the Supreme Court. The Court of Appeals correctly reversed the RTC's dismissal of the complaint, recognizing the established tenancy relationship. On the issue of raising the identity of the property for the first time on appeal: The Court held that the question of the identity of the property has never been raised in the lower court and in the respondent court. It is too well-known a rule that it is too late to raise this issue on appeal when it has not been raised either in the lower court or in the appellate court. The petitioners' claim that the property sold to Emma was smaller than the property Anulina originally purchased from Pedro Ledesma was an issue of fact regarding the identity of the land, which was not presented during the trial or the appeal to the CA. Therefore, this issue cannot be considered by the Supreme Court.
Main Doctrine
The issue of the identity of the property, not having been raised in the lower courts, cannot be raised for the first time on appeal.