G.R. No. 124516 April 24, 1998
NICOLAS CARAAN, petitioner, vs. COURT OF APPEALS, SECRETARY OF AGRARIAN REFORM, and SPOUSES MACARIO AGUILA and LEONOR LARA, respondents.

FACTS

Petitioner Nicolas Caraan’s father, Miroy Caraan, was the tenant of private respondents’ grandparents on a parcel of land consisting of riceland and an orchard. Upon the death of the grandparents, private respondents inherited the properties. Miroy also died, and petitioner occupied a portion of the orchard for his residence, planted trees, and claimed to have tilled the riceland based on an agreement between private respondents and one Benjamin Ricablanca, whom petitioner claimed was his co-tenant. Private respondents demanded that petitioner vacate the area he occupied as a residence. When he refused, they filed an ejectment case against him before the Metropolitan Trial Court (MTC). In his answer, petitioner expressed willingness to vacate provided he was reimbursed for necessary expenses incurred in maintaining the property. Apprehensive of a potential agrarian dispute, the MTC referred the case to the Department of Agrarian Reform (DAR) pursuant to Presidential Decree (P.D.) No. 316. The DAR Hearing Officer conducted an ocular inspection, received affidavits and documents, and subsequently certified the case as “proper for trial,” ruling that no tenancy relationship existed because the land was residential, petitioner was a mere sub-lessee of Ricablanca, and there was no clear proof of sharing in agricultural produce. Petitioner’s petition for a new hearing and subsequent motion for reconsideration with the DAR were denied. The DAR ordered the return of the records to the MTC for proper proceedings. Petitioner elevated the matter to the Court of Appeals, which affirmed the DAR’s findings. Hence, this petition, wherein petitioner imputes grave abuse of discretion to the Court of Appeals and prays for: (a) remand of the case to the DAR for further hearing; (b) restoration to his landholding pending the case; and (c) if restoration is not possible, allowance to exercise his right of redemption.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in affirming the DAR’s preliminary determination that no tenancy relationship existed between the parties.

RULING

The Supreme Court DISMISSED the petition and REMANDED the case to the Municipal Trial Court of San Jose, Batangas. The Court held that:
1. The petition, although denominated as a petition for certiorari under Rule 65, essentially raised errors of judgment more proper for a petition for review under Rule 45. An erroneous appreciation of facts is not an abuse of discretion but a mere error of judgment not assailable via certiorari. Nevertheless, the Court relaxed procedural technicalities in the interest of substantial justice.
2. The preliminary determination of the existence of a tenancy relationship by the DAR, when a case is referred to it by a court under the now-repealed P.D. No. 316, is not final or binding on the courts. The decree itself provides that if the Secretary finds the case proper for the court, it shall be certified as such, and the court may then assume jurisdiction. P.D. No. 1038 explicitly stated that such preliminary determination is not binding upon the court, which may confirm, reverse, or modify it after due hearing.
3. P.D. Nos. 316 and 1038 were expressly repealed by Section 76 of Republic Act No. 6657 (Comprehensive Agrarian Reform Law). Consequently, the requirement for a court to refer a case to the DAR for a preliminary determination became unnecessary. The repeal, being procedural, did not prejudice the petitioner.
4. The pending ejectment case in the MTC is the proper forum for the full ventilation of the tenancy issue. A definitive resolution by the Supreme Court on the existence of tenancy at this stage would render the ejectment case nugatory and could lead to an absurd and circuitous scenario where the Court’s findings on an incidental matter might later be reviewed and reversed by the trial court.
5. The Supreme Court is not in a position to resolve the factual dispute, as the evidence required in courts differs from that in administrative agencies.
6. Petitioner’s prayers are unmeritorious: (a) there was no evidence he was actually deprived of possession; (b) the right of redemption is dependent on the outcome of the ejectment case and is premature; (c) the prayer for dismissal of the ejectment case was not raised below and is not before the Court; and (d) remand to the DAR is unnecessary.