DIGEST, SY 2016-2017 Evid Atty.

Laurence Arroyo
ence

REYES v. CA
G.R. No. 96492, November 26, 1992
Admissibility (Rule 128, Sections 1-4)

FACTS

This case involves 2 parcels of land in Bahay Pare Estate, Bahay Pare, Candaba Pampanga (Farm Lot No. 46
and 106, 23K sqm), owned by Juan Mendoza, father of Olympio Mendoza. They produced palay, and the lands
were tenanted by spouses Julian dela Cruz and Eufrocina dela Cruz. When Julian died, Eufrocina alleged that
she succeeded Julian as bona fide tenant of the subject lots, that Olympio, in conspiracy with other defendants,
prevented her daughter Violeta and her workers through FISTS, from entering and working on the subject
premises. Reyes etc (barangay officials of Pare) denied interference in the tenancy relationship, and Olympio
raised abandonment, sublease and mortgage of the farm lots without his consent and approval, and non-
payment of rentals and other fees.

The CA ordered Olympio et al to restore possession of Lot 46 (at the agrarian court, it was held that both Lot
46 and 103 are subject to litigation), to vacate the premises, to pay jointly and severally 220 cavans of
palay/equivalent in case from 1984.

ISSUE/S

Whether Olympio et al can be held liable, jointly and severally, with other defendants for the harvests of Lot 46
YES.

HELD

At the onset, the Court held that the petitioners are asking for re-examination of all the evidence already
presented and evaluated by the trial court (so Q of Fact). The Court said that it will not analyze such evidence all
over again (cardinal and general rule that only Qs of law may be brought under Rule 45/to the SC).

The Court has also adopted CAs ratiocination regarding the findings of the lower court, namely:

1. That the only dispute here is Lot 46 (as alleged in the Complaint by the dela Cruz);
2. That the other defendants knew Olimpio personally, lending credence to the allegation that Olimpio et al
prevented the dela Cruzes from entering the land through strong arm methods; and
3. That 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 an are admissible in evidence. Moreover,
in agrarian cases, th quantum of evidence required is no more than substantial evidence. This
substantial evidence rule was incorporated in section 18, P.D. No. 946. Substantial evidence does not
necessarily import preponderant evidence, as it 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.

Arcaina Austria Baadera Cheng Coloquio Diploma Fajardo Layno Lim, J. Villarin, L. Villarin, P.1