Reyes v. Court of Appeals
REITERATIONFacts
The Antecedents: The underlying dispute concerns the tenancy rights and possession of two farm lots, Lot No. 46 and Lot No. 106, in Bahay Pare, Candaba, Pampanga. Juan Mendoza was the owner of these lots, which were tenanted and cultivated by Julian dela Cruz. Upon Julian's death in 1979, his wife, Eufrocina dela Cruz, alleged she succeeded him as the bona fide tenant. Eufrocina claimed that in July 1984, petitioners Romeo Reyes, Angel Parayao, Emilio Mananghaya, along with Olympio Mendoza and Severino Aguinaldo, conspired to prevent her daughter Violeta and her workers from accessing and cultivating the lots through force and intimidation, thereby violating her tenancy rights. The petitioners, who were barangay officials, denied interfering with the tenancy, while Olympio Mendoza raised defenses of abandonment, sublease, mortgage, and non-payment of fees. Procedural History: Eufrocina dela Cruz filed a complaint seeking recovery of possession and damages, with a preliminary mandatory injunction. The agrarian court initially ordered the defendants, including the petitioners, to restore possession of the disputed landholding to Eufrocina. During the pendency of the case, Olympio Mendoza was in possession and cultivated the lots, and the court supervised the harvesting and deposit of palay. The Court of Appeals affirmed the agrarian court's decision with a modification, excluding Lot No. 106 from the judgment. This decision by the Court of Appeals was promulgated on November 22, 1990. The agrarian court's decision was promulgated on January 10, 1990. The decision of the Court of Appeals became final and executory as to Olympio Mendoza and Severino Aguinaldo, who did not appeal. The Petition: Petitioners Romeo Reyes, Angel Parayao, and Emilio Mananghaya filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, challenging the Court of Appeals' decision. Their sole issue was whether they could be held jointly and severally liable with Olympio Mendoza and Severino Aguinaldo for the harvests of Lot No. 46, or its monetary equivalent, from 1984 onwards. Petitioners argued they were not liable because Lot No. 106 was excluded from the judgment, and Lot No. 46 was donated to the barangay for a school. They also presented a resolution from a fiscal dismissing a complaint against them for violation of P.D. 583, asserting their point was settled. They further claimed they were included to destroy their political careers. Private respondents countered that petitioners conspired in their dispossession from Lot No. 46 and sought compensation for lost income.
Issue(s)
Whether petitioners can be held liable, jointly and severally, with the other defendants for the harvests of Lot No. 46 or its money equivalent starting from the principal crop year of 1984 and every harvest time thereafter until possession is surrendered. Whether the affidavits of Eufrocina and Efren Tecson were admissible in evidence despite the affiants not being presented for cross-examination. Whether the quantum of evidence required in agrarian cases is substantial evidence.
Ruling
The petition is denied for lack of merit. The decision of the Court of Appeals is affirmed in toto.
Ratio Decidendi
On the joint and several liability for harvests: The Supreme Court held that it would not re-examine the findings of fact of the respondent Court of Appeals, as only questions of law may be raised in a petition for review on certiorari under Rule 45 of the Rules of Court, and no exceptions were present in this case. The Court agreed with the appellate court's reasoning that the petitioners, as barangay officials, were found to have participated in the dispossession of the appellee. Their knowledge of Olympio Mendoza and some being asked to help cultivate the land lent credence to the allegation that they, together with Olympio, prevented the plaintiff and her workers from entering the land through "strong arm methods." Therefore, their liability for the harvests was affirmed. On the admissibility of affidavits: The Court ruled that the trial court did not err in favorably considering the affidavits of Eufrocina and Efren Tecson, even though the affiants were not presented for cross-examination. This is because Section 16 of P.D. No. 946 provides that the Rules of Court are not applicable, even in a suppletory character, in agrarian cases. The same provision allows affidavits and counter-affidavits to be admitted as evidence in the hearing, investigation, and determination of any question or controversy. On the quantum of evidence in agrarian cases: The Supreme Court reiterated that in agrarian cases, the quantum of evidence required is substantial evidence, as incorporated in Section 18 of P.D. No. 946. The Court cited the definition of substantial evidence from Bagsican vs. Hon. Court of Appeals, stating it is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The presence of contrary evidence does not negate substantial evidence, as the appellate court cannot substitute its judgment for that of the trial court in determining the weight of evidence.
Main Doctrine
In agrarian cases, affidavits are admissible as evidence, and the quantum of proof required is substantial evidence, not necessarily preponderant evidence. The Supreme Court will not re-examine findings of fact by the lower courts in a petition for review on certiorari, absent exceptions.