GR L 59606; (January, 1987) (Digest)
G.R. No. L-59606. January 8, 1987.
EDMUNDO ROMERO, FELIZA F. ROMERO, JOSE ADORABLE and GERONIMO CASAES, petitioners, vs. THE HONORABLE COURT OF APPEALS, Ninth Division, THE HONORABLE COURT OF AGRARIAN RELATIONS, Branch II, Naga City, and TIMOTEO IBARRA, respondents.
FACTS
Private respondent Timoteo Ibarra filed an action for reinstatement with damages before the Court of Agrarian Relations (CAR), claiming to be the bona fide agricultural lessee of two parcels of land owned by petitioners. The CAR ruled in favor of Ibarra, finding through preponderance of evidence that a tenancy relationship existed. Petitioners appealed this decision to the Court of Appeals pursuant to Section 18 of Presidential Decree No. 946. The appellate court affirmed the CAR decision in toto. In its decision, the Court of Appeals adopted the findings of fact and law of the agrarian court as its basis for affirmance, as permitted by P.D. 946 when an affirmance is in toto. However, the appellate court did not issue any notice to the parties regarding the receipt of the case records from the CAR, nor did it issue a notice dispensing with the requirement for the parties to file memoranda.
ISSUE
Whether the Court of Appeals committed a reversible procedural error by affirming the CAR decision without first notifying the parties or requiring them to file memoranda, thereby violating petitioners’ right to due process.
RULING
Yes. The Supreme Court set aside the decision of the Court of Appeals and remanded the case. The legal logic is anchored on the fundamental right to due process. While Section 18 of P.D. 946 grants the Court of Appeals discretion to require simultaneous memoranda or to dispense with them, the exercise of this discretion must be communicated to the parties. The complete absence of any notice regarding the status of the appeal or the court’s action on the memorandum requirement deprived petitioners of a fair opportunity to be heard on appeal. This is a critical safeguard, especially in agrarian cases where the Court of Appeals is prohibited from entertaining motions for reconsideration. The right to appeal includes the right to be informed of the procedures being undertaken by the appellate court. By adopting the trial court’s decision without providing this basic procedural notice, the Court of Appeals effectively denied petitioners their day in court on appeal. The Supreme Court emphasized that the perception of a fair hearing is as crucial as the validity of the decision itself. Thus, the case was remanded to the Court of Appeals to allow the parties to file simultaneous memoranda on points not addressed in the adopted CAR decision, after which a new decision must be rendered.