GR L 15890; (February, 1964) (Digest)
G.R. No. L-16890 EN BANC G.R. No. L-15890; February 29, 1964
VICENTE SALAZAR, petitioner, vs. THE HON. JOSE M. SANTOS, Judge of the Court of Agrarian Relations, LEONARDO STA. ROMANA, GAUDENCIO VALDEZ, TEOFILO TINIO and PEDRO GRANETA, respondents.
FACTS
Petitioner Vicente Salazar filed a complaint in the Court of Agrarian Relations (CAR Case No. 1379-NE ’58) against respondents, alleging he was a tenant of respondent Leonardo Sta. Romana on a landholding in Nueva Ecija from 1941 to 1958, sharing the harvest on a 50-50 basis, until his alleged illegal ejectment. The respondents, except the judge, denied the existence of any tenancy relationship between Salazar and Sta. Romana. The CAR court dismissed Salazar’s petition, finding his evidence inconsistent and not credible. The court noted Salazar claimed to have dealt with overseer Gaudencio Valdez from 1941, but evidence showed Valdez was only appointed overseer in 1952. Furthermore, patrolman Pedro Graneta testified that Salazar had admitted before the mayor that the land was given to him by his father-in-law, Emiliano Feliciano, who appointed him as tenant.
ISSUE
The core issue is whether the Court of Agrarian Relations committed reversible error in dismissing Salazar’s petition and ruling that no tenancy relationship existed between him and landholder Leonardo Sta. Romana.
RULING
The Supreme Court affirmed the decision of the Court of Agrarian Relations. The legal logic rests on the evaluation of evidence and the effect of prior related proceedings. The Supreme Court deferred to the factual findings of the CAR, which was in a better position to assess the credibility of witnesses and evidence. The CAR found Salazar’s testimony inconsistent and gave credence to the testimony of an apparently disinterested witness, patrolman Graneta, whose account suggested Salazar was merely a subtenant or helper of his father-in-law, not a direct tenant of Sta. Romana.
Regarding the prior decisions of the Court of Industrial Relations (CIR) cited by Salazar, the Court held they did not establish a binding tenancy relationship with Sta. Romana. In CIR Case Nos. 1647-R-1652-R, Salazar was declared in default, and the decision did not squarely rule on his status vis-à-vis Sta. Romana, who was not a party. In CIR Case No. 1965-NE, the court explicitly dismissed Salazar’s claim for liquidation due to failure to establish the tenancy relationship. While not res judicata, this prior decision was properly considered by the CAR as relevant material in assessing the factual situation. The Supreme Court found no error in the CAR’s conclusion that Salazar failed to substantiate his claim of being a bona fide tenant of respondent Sta. Romana.