G.R. No. 107493 ; February 1, 1996
NATIVIDAD CANDIDO, assisted by her husband ALFREDO CANDIDO, and VICTORIA C. RUMBAUA, assisted by her husband AMOR RUMBAUA, petitioners, vs. COURT OF APPEALS and SOFRONIO DABU, respondents.

FACTS

Petitioners Natividad Candido and Victoria Rumbaua, co-owners of an irrigated riceland in Orion, Bataan, filed a complaint before the Regional Trial Court (RTC) against their agricultural tenant, respondent Sofronio Dabu. They sought termination of the tenancy relationship and recovery of unpaid rentals starting from the 1983 crop year. Petitioners alleged that a team from the Ministry of Agrarian Reform (MAR) had fixed provisional rental rates of 26 and 29 sacks of palay for the rainy and dry seasons, respectively, which Dabu failed to pay. Dabu countered that their sharing system was on a 50-50 basis until 1983, denied knowledge of any MAR-fixed provisional rentals, and claimed he had made payments by depositing palay for specified seasons.
Upon Dabu’s motion, the case was referred to the Department of Agrarian Reform (DAR) for a preliminary determination. The DAR certified the case as proper for trial, but only on the issue of non-payment of rentals, not ejectment. During trial, petitioners presented their Transfer Certificate of Title and tax declaration but failed to formally offer in evidence the affidavit of Natividad Candido and any MAR certification detailing the alleged provisional rental rates.

ISSUE

Whether the trial court and the Court of Appeals correctly dismissed the complaint for failure of petitioners to establish their cause of action for non-payment of agricultural rentals.

RULING

Yes. The Supreme Court affirmed the dismissal. The core legal principle applied is that courts can only consider evidence that has been formally offered. Petitioners’ critical documents—the affidavit mentioning the provisional rental rates and the alleged MAR certification—were merely marked for identification but never formally offered as evidence during trial. Consequently, under Section 34, Rule 132 of the Revised Rules of Court, these documents cannot be considered by the court. The opposing party must be given the opportunity to object to the admissibility of evidence, and judges must base their decisions strictly on evidence offered at trial.
The Court rejected petitioners’ argument that judicial notice should be taken of the affidavit, as it does not fall under the mandatory categories specified in Rule 129. Petitioners’ own testimony was deemed unreliable, as Natividad Candido could not precisely recall when the defaults began or the harvest volumes. Since petitioners failed to substantiate the existence of the MAR-fixed provisional rentals or prove Dabu’s non-compliance, they did not discharge their burden of proof. The appellate court correctly confirmed the trial court’s finding that no evidence supported the alleged breach, and the prevailing 50-50 sharing arrangement was upheld. The petition was denied for failure to establish a cause of action.