5 Reyes, Parayao and Mananghaya vs.
CA, Dela Cruz controversy, affidavits and counter-affidavits may be allowed
GR No. 96492 | November 26, 1992 and are admissible in evidence.”
Nocon, J.
Evidence required in agrarian cases
DOCTRINE Moreover, in agrarian cases, the quantum of evidence required
Rules of Court shall not be applicable in agrarian cases even in is no more than substantial evidence, as incorporated in
a suppletory character. section 18, P.D. No. 946. Substantial evidence does not
necessarily import preponderant evidence, as is required in an
FACTS ordinary civil case. It has been defined to be such relevant
Juan Mendoza, father of Olympio Mendoza, is the owner of evidence as a reasonable mind might accept as adequate to
Farm Lots No. 46 and 106 of the Bahay Pare Estate in support a conclusion and its absence is not shown by stressing
Pampanga. The lots were tenanted and cultivated by Julian that there
Dela Cruz, husband of respondent Eufrocina dela Cruz. Julian is contrary evidence on record, direct or circumstantial, for the
died. appellate court cannot substitute its own judgment or criteria
for that of the trial court in determining wherein lies the weight
Eufrocina filed a case for recovery of possession and damages of evidence or what evidence is entitled to belief.
against Olympio Mendoza and petitioners, in conspiracy with
each other. Dela Cruz alleged that her daughter Violeta and On the conspiracy between petitioners and Mendoza
her workers were prevented by petitioners through force, Petitioners not only knew Olimpio personally, some of them
intimidation, strategy and stealth, from entering the lots. were even asked by Olimpio to help him cultivate the land, thus
lending credence to the allegation that Olimpio, together with
Petitioners, who are barangay officials of Bahay Pare, moved petitioners, prevented respondents and her workers from
to dismiss the case, denying interference in the tenancy entering the land through strong arm methods.
relationship; contending that they exercised fairness at all
times. Mendoza also moved for the dismissal raising Denied.
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
HELD
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
