Candido v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Petitioners Natividad Candido and Victoria Rumbaua, co-owners of a riceland, filed a complaint against their agricultural tenant, respondent Sofronio Dabu, for termination of tenancy and recovery of unpaid rentals. Petitioners alleged that respondent failed to pay the provisional rental of twenty-six (26) and twenty-nine (29) sacks of palay for the rainy and dry seasons, respectively, as fixed by the Ministry of Agrarian Reform, starting from the crop year 1983. Respondent denied these allegations, asserting a 50-50 sharing basis until 1983 and claiming he had paid his rentals by depositing specific quantities of palay. He also disputed the existence of any provisional rental fixed by the Ministry of Agrarian Reform. 2. Procedural History: The Regional Trial Court of Bataan initially dismissed the petitioners' complaint for failure to establish their cause of action. This dismissal was affirmed by the Court of Appeals, which found no evidence presented by the petitioners to prove the alleged provisional rental rates fixed by the Ministry of Agrarian Reform or the actual amount of net harvest after expenses. The appellate court noted that crucial documents, such as an affidavit of one petitioner and a certification from the Ministry of Agrarian Reform, were never formally offered as evidence. A motion for reconsideration by the petitioners was noted, as such motions are not permitted in agrarian cases under the Revised Internal Rules of the Court of Appeals. 3. The Petition: This case reaches the Supreme Court via a petition for review on certiorari filed by the petitioners. They seek to re-examine the decision of the Court of Appeals, arguing that the trial court erred in not taking cognizance of their verified complaint and affidavit presented to the Department of Agrarian Reform as proof of the provisional rentals. Petitioners contend that these documents should have been considered evidence. The Supreme Court, however, found no merit in the petition, affirming the lower courts' decisions based on the principle that evidence must be formally offered to be considered, and that judicial notice cannot be taken of the alleged provisional rates as they do not fall under mandatory or public knowledge categories.
Issue(s)
Whether the petitioners sufficiently established their cause of action for unpaid rentals. Whether the verified complaint and affidavit presented to the DAR, without formal offer, could be considered as evidence of the provisional rental rates. Whether the courts should have taken judicial notice of the affidavit of petitioner Natividad Candido.
Ruling
The petition is denied. The decision of the Court of Appeals affirming the dismissal of the complaint is affirmed.
Ratio Decidendi
On the issue of establishing a cause of action: The Court found that the petitioners failed to establish their cause of action. They did not prove that respondent Dabu failed to pay his rentals starting in 1982 or 1983, nor were they able to competently confirm the provisional rate of rentals allegedly fixed by the Ministry of Agrarian Reform. The testimony of petitioner Natividad Candido was found unreliable as she could not recall precisely when the alleged failure to pay began and did not know the exact harvest yield per crop-year. On the admissibility of the verified complaint and affidavit as evidence: The Court reiterated the settled rule that courts will only consider evidence that has been formally offered. The affidavit of petitioner Natividad Candido, which mentioned the provisional rate of rentals, was never formally offered in evidence. Similarly, the alleged certification by the Ministry of Agrarian Reform was not formally offered. Therefore, both the trial court and the appellate court correctly disregarded these documents as they were not formally presented and the opposing counsel was not given an opportunity to object or cross-examine. On the issue of judicial notice: The Court held that it could not take judicial notice of the affidavit of petitioner Natividad Candido. The affidavit was not among the matters that the law mandatorily requires to be taken judicial notice of, nor could it be considered as public knowledge or capable of unquestionable demonstration. The Court emphasized that judicial notice is limited to specific categories outlined in the Revised Rules of Court, and the contents of a private affidavit do not fall within these exceptions.
Main Doctrine
A party must formally offer evidence for it to be considered by the court. Documents not formally offered, even if attached to pleadings or mentioned in affidavits, cannot be considered as evidence. Courts are mandated to base their findings of fact and judgment strictly upon the evidence formally offered by the parties.