G.R. No. 96492 November 26, 1992
ROMEO REYES, ANGEL PARAYAO, and EMILIO MANANGHAYA, petitioners, vs. THE COURT OF APPEALS, EUFROCINA DE LA CRUZ and VIOLETA DELOS REYES, respondents.

FACTS

Juan Mendoza owned Farm Lots Nos. 46 and 106 in Bahay Pare, Candaba, Pampanga, which were tenanted and cultivated by Julian dela Cruz. Upon Julian’s death on September 25, 1979, his wife, Eufrocina dela Cruz, succeeded him as tenant. Eufrocina alleged that between July 7 to 15, 1984, Olympio Mendoza (Juan’s son), in conspiracy with the other defendants—including petitioners Romeo Reyes, Angel Parayao, and Emilio Mananghaya (who were barangay officials)—prevented her and her workers through force, intimidation, strategy, and stealth from entering and working on the landholdings. The defendants refused to vacate, violating her tenancy rights. The defendants denied interference, claiming impartiality in their official functions, while Olympio Mendoza raised defenses of abandonment, sublease, and non-payment of rentals by the tenant. During the case, the court directed the harvest to be deposited subject to its disposition. The agrarian court ordered defendants to restore possession to Eufrocina and pay 220 cavans of palay or its cash equivalent from 1984 until they vacate. The Court of Appeals affirmed the decision but modified it by excluding Lot 106 from the judgment. Petitioners, in this Supreme Court appeal, question their joint and several liability for the harvests of Lot No. 46.

ISSUE

Whether or not petitioners Romeo Reyes, Angel Parayao, and Emilio Mananghaya can be held liable, jointly and severally, with the other defendants for the harvests of Lot No. 46 or its monetary equivalent starting from the 1984 crop year until possession is restored to the private respondent.

RULING

The Supreme Court DENIED the petition and AFFIRMED the decision of the Court of Appeals in toto. The Court held that the petition essentially asked for a re-examination of evidence, which is a question of fact, not permissible in a petition for review on certiorari under Rule 45 of the Rules of Court. The Court adopted the appellate court’s reasoning, which found that the trial court did not err in considering affidavits despite the affiants not being cross-examined, as Section 16 of P.D. No. 946 provides that the Rules of Court are not applicable in agrarian cases and allows affidavits as admissible evidence. Furthermore, the quantum of evidence required in agrarian cases is substantial evidence, which was met. The appellate court also concurred with the trial court’s finding on the petitioners’ participation in the dispossession, noting they knew Olympio Mendoza personally and some were even asked by him to help cultivate the land, lending credence to the allegation of “strong arm methods.” Thus, petitioners were solidarily liable with the other defendants.