Caraan v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Nicolas Caraan, approximately 90 years old, occupied a portion of an orchard inherited by private respondents Spouses Macario Aguila and Leonor Lara. Petitioner claimed to have planted trees and tilled the riceland by virtue of an agreement, asserting a co-tenancy with one Benjamin Ricablanca. Private respondents demanded petitioner vacate the residential portion. Procedural History: Petitioner refused to vacate, prompting private respondents to file an ejectment case and damages before the Metropolitan Trial Court (MTC). Petitioner expressed willingness to vacate if reimbursed for expenses. The MTC, apprehending an agrarian dispute, referred the case to the Department of Agrarian Reform (DAR) pursuant to Presidential Decree (P.D.) 316. The DAR Hearing Officer conducted an ocular inspection, received affidavits and documents, and certified the case as "proper for trial," ruling that no tenancy relationship existed as the land was residential, not orchard, and petitioner was a mere sub-lessee without proof of sharing in produce. Petitioner's motion for new hearing and reconsideration with the DAR were denied. The DAR eventually ordered the return of records to the MTC. Petitioner then elevated the matter to the Court of Appeals (CA), which affirmed the DAR's finding. The Petition: Petitioner filed a petition for certiorari under Rule 65 with the Supreme Court, imputing grave abuse of discretion to the CA for affirming the DAR's finding of no tenancy relationship. Petitioner prayed for remand to DAR for further hearing, restoration to his landholding, and the right of redemption if restoration was impossible.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in affirming the DAR's finding that no tenancy relationship existed between the parties. Whether a petition for certiorari under Rule 65 is the proper remedy to assail the Court of Appeals' appreciation of facts. Whether the preliminary determination of the DAR regarding a tenancy relationship is binding on the courts. Whether the repeal of P.D. 316 by R.A. 6657 renders the reference to the DAR unnecessary, and the proper forum for resolution, including prayers for restoration and redemption.
Ruling
The petition is DISMISSED. The case is REMANDED to the Municipal Trial Court of San Jose, Batangas.
Ratio Decidendi
On the existence of a tenancy relationship and the alleged grave abuse of discretion: The Court found itself not in a position to resolve the dispute due to differing evidence requirements between administrative agencies and courts, and stated that the ejectment case is the proper forum for the full ventilation of the tenancy issue. A definitive ruling by the Supreme Court on the tenancy issue at this stage would render the ejectment case pending in the trial court nugatory. On the propriety of the remedy: The Court held that the petition, though denominated as one for certiorari under Rule 65, assigned errors more properly addressed in a petition for review under Rule 45. The alleged erroneous appreciation of facts by the respondent court was deemed a mere error of judgment, not an act of grave abuse of discretion, which cannot be assailed through a Rule 65 petition. A review of facts and evidence is not the province of the extraordinary remedy of certiorari. Nevertheless, in the interest of substantial justice, the Court proceeded to rule on the merits. On the preliminary determination by the DAR: The Court clarified that the referral of the ejectment case to the DAR under P.D. 316 was for a preliminary determination of the agrarian relationship. This determination is not binding upon the courts, which may confirm, reverse, or modify it based on the evidence and merits of the case, as provided in P.D. 1038. The DAR's certification that a case is proper for court action allows the court to assume jurisdiction, but the court is not bound by the DAR's initial appreciation of the relationship. On the effect of the repeal of P.D. 316 and other considerations: The Court noted that P.D. 316 was expressly repealed by R.A. 6657. Consequently, the reference to the DAR became unnecessary, as trial courts may now proceed to hear the case directly. The repeal of this procedural requirement did not prejudice the petitioner. Furthermore, even if a tenancy relationship were determined by the DAR, it would not necessarily preclude an ejectment case from prospering. The Court found no evidence that petitioner was deprived of possession, as the private respondents filed suit precisely because of his refusal to vacate. The prayer for the right of redemption was deemed premature, being dependent on the outcome of the ejectment case. The prayer for remand to the DAR was deemed unnecessary.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy to assail alleged erroneous appreciation of facts by the Court of Appeals; such is a mere error of judgment, not an act of grave abuse of discretion. Furthermore, the preliminary determination of a tenancy relationship by the Department of Agrarian Reform (DAR) under P.D. 316 is not binding upon the courts, which may confirm, reverse, or modify it based on the evidence presented.