5 Reyes, Parayao and Mananghaya vs.
CA, Dela HELD
Cruz
GR No. 96492 | November 26, 1992
Nocon, J.
DOCTRINE
Rules of Court shall not be applicable in agrarian
cases even in a suppletory character.
FACTS
Juan Mendoza, father of Olympio Mendoza, is the
owner of Farm Lots No. 46 and 106 of the Bahay
Pare Estate in Pampanga. The lots were tenanted
and cultivated by Julian Dela Cruz, husband of
respondent Eufrocina dela Cruz. Julian died.
Eufrocina filed a case for recovery of possession
and damages against Olympio Mendoza and
petitioners, in conspiracy with each other. Dela
Cruz alleged that her daughter Violeta and her
workers were prevented by petitioners through
force, intimidation, strategy and stealth, from
entering the lots.
Petitioners, who are barangay officials of Bahay
Pare, moved to dismiss the case, denying
interference in the tenancy relationship;
contending that they exercised fairness at all
times. Mendoza also moved for the dismissal
raising abandonment, sublease and mortgage of
the farm lots without consent and approval and
non-payment of rental fees.
The agrarian court favored respondents and
ordered petitioners and Mendoza to restore
possession of the disputed landholding.
CA affirmed, with the modification that Lot 106 is
not covered by it. It ordered petitioners and
Mendoza jointly and severally to pay 220 cavans of
palay or its cash equivalent.
Hence, this petition. Only petitioners appealed the
case. the CA decision became final as to Olympio
Mendoza. Petitioners contend that they are not
liable jointly and severally because the present
petition involves Lot 46 and not Lot 106, which lot
was purchased by petitioner Reyes from Olympio
Mendoza’s father, and which later, was donated to
Barangay Bahay Pare. They also presented the
fiscal’s resolution dismissing the complaint
against them before the agrarian court, thus, case
is closed.
ISSUE
Whether it was correct to admit as evidence the
affidavits of Eufrocina Dela Cruz and Efren Tecson
evidence although the affiants were not presented
and subjected to cross-examination
Yes.
Basically, the petitioners would want the SC to re-
examine the evidence. The evidence presented
before the trial court and CA served as basis in
arriving at their findings of fact. The Supreme
Court will not analyze such evidence all over again
because settled is the rule that only questions of
law may be raised in a petition for review
on certiorari under Rule 45 of the Rules of
Court absent the exceptions which do not obtain
in the instant case.
Section 16 of P.D. No. 946 provides that the “Rules
of Court shall not be applicable in agrarian cases
even in a suppletory character.” The same
provision states that “In the hearing, investigation
and determination of any question or controversy,
affidavits and counter-affidavits may be allowed
and are admissible in evidence.”
Evidence required in agrarian cases
Moreover, in agrarian cases, the quantum of
evidence required is no more than substantial
evidence, as incorporated in section 18, P.D. No.
946. Substantial evidence does not necessarily
import preponderant evidence, as is required in an
ordinary civil case. It has been defined to be such
relevant evidence as a reasonable mind might
accept as adequate to support a conclusion and
its absence is not shown by stressing that there
is contrary evidence on record, direct or
circumstantial, for the appellate court cannot
substitute its own judgment or criteria for that of
the trial court in determining wherein lies the
weight of evidence or what evidence is entitled to
belief.
On the conspiracy between petitioners and
Mendoza
Petitioners not only knew Olimpio personally,
some of them were even asked by Olimpio to help
him cultivate the land, thus lending credence to
the allegation that Olimpio, together with
petitioners, prevented respondents and her
workers from entering the land through strong arm
methods.
Denied.