Heirs of Barraquio v. Almeda
REVERSALFacts
The Antecedents: This case concerns the validity of Certificates of Land Ownership Award (CLOAs) issued to the late Domingo Barraquio for certain properties. The core dispute revolves around whether these properties are classified as agricultural land, thus falling under the Comprehensive Agrarian Reform Program (CARP), or if they are exempt due to their classification as industrial land. The heirs of Domingo Barraquio maintain the CLOAs are valid, while Almeda Incorporated asserts the properties are industrial and thus exempt from CARP. Procedural History: The case has a lengthy procedural history involving multiple lower court and appellate court decisions. Initially, the Department of Agrarian Reform (DAR) issued CLOAs to Domingo Barraquio. Almeda Incorporated challenged this, leading to various rulings and appeals. The Court of Appeals, in a Resolution dated July 23, 2008, affirmed the cancellation of the CLOAs. The Supreme Court, in a January 16, 2023 Decision, initially granted the petitions of the heirs, upholding the validity of the CLOAs. However, Almeda Incorporated filed a Motion for Reconsideration, leading to the present resolution. The Petition: This resolution addresses Almeda Incorporated's Motion for Reconsideration of the Supreme Court's January 16, 2023 Decision. Almeda Incorporated argues that newly discovered evidence presented by the petitioners (2013 Certifications from HLURB and the City of Santa Rosa) is hearsay and should not have been admitted, as it was not discovered with reasonable diligence and was presented out of time. They also reiterate arguments regarding forum shopping and the Court of Appeals' discretion. The petitioners, in turn, argue that the motion is a rehash of previously decided issues. The Supreme Court, upon re-examination, grants the Motion for Reconsideration, finding that the 2013 Certifications do not qualify as newly discovered evidence and that the properties are indeed exempt from CARP coverage based on the evidence presented by Almeda Incorporated.
Issue(s)
Whether the certification presented by petitioners constitutes newly discovered evidence, and whether petitioners exercised reasonable diligence in discovering and presenting the evidence. Whether the subject properties are exempt from the Comprehensive Agrarian Reform Program (CARP). Whether the Court of Appeals gravely abused its discretion in issuing its July 23, 2008 Resolution, and whether petitioners were guilty of forum shopping.
Ruling
The Supreme Court granted the respondent's Motion for Reconsideration. The Court affirmed the Court of Appeals' March 30, 2005 Decision and September 9, 2005 Resolution, and the July 23, 2008 and November 17, 2008 Resolutions. The cancellation and/or nullification of the Certificates of Land Ownership Award (CLOAs) issued in favor of Domingo Barraquio (CLO-1409 and 1375) were affirmed. The properties are not covered by the Comprehensive Agrarian Reform Program (CARP) under Republic Act No. 6657.
Ratio Decidendi
On the admissibility of newly discovered evidence and diligence: The Court reiterated that for evidence to be considered newly discovered, it must have been discovered after trial, could not have been discovered and produced at trial even with reasonable diligence, must be material and not merely cumulative, and must be of such weight that it would change the judgment. Furthermore, such evidence must be presented through a motion for new trial within the period for taking an appeal or before the appellate court loses jurisdiction. In this case, the petitioners filed their motion after their Rule 45 Petition, rendering it improper and out of time. Moreover, they failed to sufficiently show why the evidence, particularly the 2013 Certifications and the underlying SB Municipal Ordinance No. 18, Series of 1981, could not have been presented earlier despite reasonable diligence. The Court emphasized that forgotten evidence, which is known to and obtainable by the party but not presented due to oversight, is not newly discovered evidence and its presentation is disallowed as it leads to piecemeal presentation and delays proceedings. The Court stressed that the movant must prove, not merely allege, that the evidence could not have been presented during trial despite reasonable diligence. The key is the failure to secure or locate the evidence despite reasonable diligence before or during trial. The party must establish why the evidence was not presented earlier. In the absence of such proof, the evidence amounts to "forgotten" evidence. The Court found that petitioners did not sufficiently show that the 2013 Certifications were suppressed or that they could not have been obtained earlier. The underlying SB Municipal Ordinance No. 18, Series of 1981, which could have provided crucial proof of classification, was also not presented, and no explanation was given for this failure. Therefore, the evidence could not be deemed newly discovered. On the exemption from CARP: Since the 2013 Certifications were not considered, the Court weighed the remaining evidence. The respondent relied on the DAR secretary's Exemption Order, supported by certifications from HLURB and the Zoning Officer of Santa Rosa, Laguna, indicating the properties were zoned for industrial use pursuant to the approved General Land Use Plan of Santa Rosa, Laguna, and Municipal Ordinance No. XVIII, Series of 1981. These were corroborated by a Reply Letter confirming the consistency of zoning ordinances and a portion of the Municipal Ordinance itself classifying the Almeda properties for industrial use. While the exact titles were not enumerated in the DAR Secretary's Order, petitioners failed to present the rest of the ordinance to contradict the conclusion. Petitioners relied on a CLUPPI Exemption Committee Memorandum stating the landholdings were within the agricultural zone in the 1981 Approved Zoning Ordinance, a letter from HLURB director questioning the earlier certification, a letter seeking clarification from a Zoning Officer, and Kautusang Bayan Blg. 237-'95 which indicated a change in classification from agricultural to industrial use only in 1995. However, given the procedural infirmity of the newly discovered evidence and the weight of the respondent's evidence, the Court ruled in favor of the respondent. On the Court of Appeals' discretion and forum shopping: The Court found that the Court of Appeals did not gravely abuse its discretion. The respondent's arguments regarding the procedural lapses of petitioners in failing to attach supporting papers and the subsequent commission of forum shopping were considered. The Court noted that the parties, causes of action, and reliefs sought in the different petitions were similar, and petitioners failed to disclose the pendency of other cases, which would result in res judicata. However, the primary basis for the resolution was the failure to properly present newly discovered evidence and the substantive merits of the CARP exemption claim.
Main Doctrine
A motion for reconsideration based on newly discovered evidence must comply with the requisites of Rule 37 or Rule 53 of the Rules of Court, including the demonstration that the evidence could not have been discovered and produced at trial even with the exercise of reasonable diligence, and that it is of such weight that it would change the judgment. Failure to comply with procedural rules regarding the timing and manner of presenting such evidence renders the motion improper.