Bautista vs Araneta

326 SCRA 234

Facts:

Plaintiff alleged that he is the lawful tenant and actual possessor of THREE (3) HECTARES parcel of land,
formerly owned by Gregorio Araneta II. Tenancy relationship between the former owner and plaintiff
started way back in 1978. However, plaintiff’s peaceful possession and cultivation was disturbed and,
even interrupted, when a group of armed security guards, through force and intimidation, entered the
subject landholding and threatened plaintiff with bodily harm. These group of armed security guards,
allegedly, were sent by herein defendant Patty Araneta, successor of Gregorio Araneta II. They warned
plaintiff to vacate and to stop cultivating the subject landholding. Thereafter, plaintiff filed a complaint
and prayed before the Department of Agrarian Reform Adjudication Board the issuance of a preliminary
injunction, during the pendency of the case, for the maintenance of status quo.c

In her Answer, defendant contended that plaintiff has no cause of action against her as the former is not
a tenant on the subject landholding. She added that the subject landholding does not fall under the
coverage of the comprehensive Agrarian Reform Law of 1988 (CARL) as it appears to be 18% in slope.

The Provincial Adjudicator of Bulacan then decided in favor of petitioner and held that he is a bona fide
tenant over the land. On appeal, the Department of Agrarian Reform Adjudication Board 4 affirmed the
decision of the Provincial Adjudicator. 

On appeal, the Court of Appeals reversed the decision of the DARAB. It held that "tenancy is not purely a
factual relationship dependent on what the alleged tenant does upon the land. It is also a legal
relationship that can only be created with the consent of the true and lawful landholder.

Hence, this appeal. Petitioner assails the decision of the CA. It erred in disregarding the settled
jurisprudence that the factual findings of administrative agencies when supported by substantial
evidence should be final and conclusive.

Issue:

WON the CA erred in disregarding the settled jurisprudence that the factual findings of administrative
agencies when supported by substantial evidence should be final and conclusive.

Ruling:

No, the court cannot sustain petitioner’s argument that he is a tenant by virtue of the factual finding of
the DARAB. DARAB through its Agrarian Reform Program Technician (ARPT) Ms. Virginia B. Domuguen
mainly relied on the certifications issued in favor of petitioner in holding that he is a tenant in the
disputed landholding. 

In Oarde v. Court of Appeals, the court held that certifications issued by administrative agencies or
officers that a certain person is a tenant are merely provisional and not conclusive on courts. This Court
is not necessarily bound by these findings specially if they are mere conclusions that are not supported
by substantial evidence.
Samson vs Ombudsman
439 SCRA 325

Facts:

Petitioner Moises S. Samson, on behalf of unidentified complainants, charged private respondents Dr.
Leonito L. Catarroja and Norma Sanchez, Chiefs of the Quezon City Health Sanitation and Food and
Drugs Divisions, respectively, with violation of paragraphs (b), (e) and (h) of Section 3 of RA 3019.

That respondent Leonito Catarroja caused the printing of health certificates without serial numbers at
his own expense and thereafter, he sold and parted with the said blank and already signed health
certificates at P20.00 each to co-respondent Norma Sanchez and likewise to an unnamed employee of
the Business Permits and Licenses Office (BPLO), Office of the Mayor, Quezon City, who then re-sold the
same to fixers. In turn, the said fixers disposed of the health certificates to applicants for  P70.00 each
without official receipt.

Private respondents counter-alleged that petitioner had neither the personality to sue nor personal
knowledge of the veracity of the complaint, which was mere hearsay, not having been supported by any
affidavit from the purportedly affected, if not fictitious, health certificate applicants or sanitary
inspectors. Also, petitioner did not present any of his witnesses before the investigating committee
created by then Quezon City Mayor Ismael Mathay. Thus, private respondents filed counter-charges
against petitioner for libel, falsification and perjury.

Thereafter, public respondent issued a joint resolution dismissing the cases filed by both parties. Hence,
this petition imputing grave abuse of discretion on the part of public respondent for dismissing a
supposedly prima facie graft case against private respondents.

Issue: WON the Ombudsman can be compelled by mandamus to reverse its findings and dispositions.

Ruling:

No, the Constitution and RA 6770 (the "Ombudsman Act of 1989") endowed the Office of the
Ombudsman with a wide latitude of investigatory and prosecutorial powers, virtually free from
legislative, executive or judicial intervention, in order to insulate it from outside pressure and improper
influence.

The public respondent cannot be compelled by mandamus to reverse its findings and dispositions.

Mandamus will not lie in the absence of any of the following grounds:

[a] that the court, officer, board, or person against whom the action is taken, unlawfully neglected the
performance of an act which the law specifically enjoins as a duty resulting from office, trust, or station,
or
[b] that such court, officer, board or person has unlawfully excluded the petitioner from the use and
enjoyment of a right or office to which he is entitled.
Mandamus will lie to compel an officer to perform a ministerial duty but not to compel the performance
of a discretionary duty requiring the exercise of judgment, as in this case.
Bernaldo vs Ombudsman
562 SCRA 60

Facts:

The Department of Public Works and Highways (DPWH) had nine (9) river dredging projects in Bataan
sometime in 1987 to 1988 which were awarded to various private contractors. The Almacen River II
Project was awarded to L.J. Cruz Construction. The contractor was allowed to commence work on
December 22, 1987 and it reported the project's completion on August 31, 1988. At the time of the
reported completion, petitioner Bernaldo was the DPWH Region III Project Engineer for the Almacen
River II Project. In a Statement of Work Accomplished dated August 31, 1988 and a Certificate of Final
Inspection and Certificate of Final Acceptance dated September 1, 1988, the Almacen River II Project was
certified 100% completed "in accordance with the approved plans and specifications" by the contractor
and the DPWH Region III Engineers.

However, a contrary finding as to the accomplishment of works involving all three projects was reported
by a Survey and Investigation Team of the Bureau of Design of the DPWH. Based on the foregoing
reports, the DPWH Region III Engineers connected with the Calaguiman River, Almacen River I, and
Almacen River II Projects were all administratively charged for Falsification, Dishonesty, and Conduct
Prejudicial to the Best Interest of the Service before the Administrative Adjudication Bureau (AAB) of the
Office of the Ombudsman. The AAB recommended the dismissal of the complaint against the DPWH
Region III Engineers, including petitioner Bernaldo, for insufficiency of evidence. However, in an  Order by
Ombudsman Aniano A. Desierto disapproved the recommendation of the AAB and, instead, found the
DPWH Region III Engineers administratively liable for "conduct grossly prejudicial to the best interest of
the service." Thus, the respondent DPWH Region III Engineers, including petitioner Bernaldo, were
ordered suspended for a period of nine (9) months without pay and other benefits.

On appeal, the CA pointed out that the reports of the Survey Team were insufficient to hold the
engineers administratively liable. However, this ruling of the CA was different in the case of petitioner
Bernaldo. The CA held that the factual findings of the Office of the Ombudsman were supported by
substantial evidence to hold petitioner Bernaldo administratively liable. Hence, the instant petition
for certiorari. The respondents, through the Solicitor General, argue that the instant petition raises
questions of fact which is beyond the scope of Rule 45 of the Rules of Court.

Issue: WON the petition raises questions of fact which is beyond the scope of Rule 45 of the Rules of
Court.

Ruling:

No,  the principle that it is well-settled that Rule 45 of the Rules of Court which provides that only
questions of law shall be raised in an appeal by certiorari under Rule 45 of the Rules of Court before this
Court admits of certain exceptions, namely: (1) when the findings are grounded entirely on speculations,
surmises, or conjectures.

To be sure, when the lower court or the administrative tribunal lower court/tribunal fails to take into
account certain relevant facts which, if properly considered, would justify a different conclusion is
likewise an accepted exception to the prescription under Rule 45.
In the petition at bar, the Ombudsman's factual finding that the percentage of completion of the
Almacen River II Project has been bloated in the Statement of Work Accomplished and the Certificate of
Final Inspection and Certificate of Final Acceptance signed by petitioner is not supported by substantial
evidence but, rather, grounded entirely on unreliable, speculative evidence which may be susceptible to
a different interpretation.

This Court has consistently held that substantial evidence is all that is needed to support an
administrative finding of fact. This is not to say, however, that administrative tribunals may rely on
flimsy, unreliable, conjectural evidence. Substantial evidence is such relevant evidence that a reasonable
mind might accept as adequate to support a conclusion. Where the decision of the Ombudsman is not
supported by substantial evidence, but based on speculations, surmises and conjectures, as in the
present case, this Court finds sufficient reason to overturn the same.