GR L 22243; (November, 1968) (Digest)
March 12, 2026GR 174938; (October, 2014) (Digest)
March 12, 2026G.R. No. 55318 February 9, 1993
ANGELES MALATE, NORBERTO ESGUERRA and BENEDICTO ESGUERRA, petitioners, vs. HONORABLE COURT OF APPEALS, and FELINO GEMANIL, respondents.
FACTS
The petitioners, Angeles Malate, Norberto Esguerra, and Benedicto Esguerra, claimed to be tenants of a landholding originally owned by Feliciana Bautista, mother of private respondent Felino Gemanil. In 1939, Feliciana Bautista instituted Francisco Esguerra (father of Norberto and Benedicto) and Artemio Gonzales (uncle of Angeles) as tenants. In 1961, due to old age, Francisco Esguerra instituted his sons Norberto and Benedicto as tenants, and Artemio Gonzales instituted his nephew Angeles Malate as tenant, both with the consent of Feliciana Bautista. The sharing agreement was 75% for the tenants and 25% for the landowner. Petitioners religiously delivered the landowner’s share to Feliciana Bautista and, after her death, to her sister Matea Bautista until Matea’s death. In 1976, private respondent Felino Gemanil requested petitioners to allow him to plant sugarcane on the landholding for three years, promising them 15% of the gross harvest as their share without any duties except supervision. Petitioners acceded, but private respondent reneged on his promise for three years and refused to reinstate petitioners to the landholding. Petitioners filed a complaint with the Court of Agrarian Relations, which ruled in their favor. On appeal, the Court of Appeals reversed the decision.
ISSUE
Whether the Court of Appeals erred in reversing the findings of fact of the Court of Agrarian Relations.
RULING
Yes, the Court of Appeals erred. The Supreme Court reinstated the decision of the Court of Agrarian Relations. In agrarian cases, the appellate court’s function is limited to determining whether the agrarian court’s findings of fact are supported by substantial evidence, defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The findings of the Court of Agrarian Relations, based on the clear, direct, and corroborated testimony of petitioners and their witness, were supported by substantial evidence. The testimony of private respondent was found incoherent, contradictory, and unworthy of belief by the trial court. Therefore, the Court of Appeals should not have substituted its own findings of fact. The Supreme Court reversed the Court of Appeals decision and reinstated the agrarian court’s judgment ordering the reinstatement of petitioners as tenants, enforcement of the 75-25 sharing arrangement, payment of unpaid shares and damages, and dismissal of claims against other defendants.
