G.R. No. L-18492. March 31, 1964.
Mamerto Tubera, et al., petitioners, vs. Margarita Fernando, respondent.

FACTS

The petitioners, tenants of respondent Margarita Fernando, filed a case before the Court of Agrarian Relations (CAR). They alleged that Fernando refused to give their harvest shares for the crop years 1956-1960 without just cause and exacted usurious interest on loans. The parties entered into a partial “Stipulation of Facts,” agreeing on a 50-50 sharing ratio per their contracts but leaving material issues contested. These included whether petitioners shouldered one-fourth of transplanting expenses, whether they used fertilizer supplied by Fernando, and the validity of claims regarding usury and proper accounting.
The CAR rendered judgment, applying the legal sharing formula under Section 42 of Republic Act No. 1199 for first-class ricelands, resulting in a 55-45 division in favor of the landowner. The court found that the petitioners used fertilizer based on evidence of widespread use among Fernando’s other tenants and that the memoranda of indebtedness did not prove usury. It also held that the CAR was not strictly bound by procedural rules on verifying usury allegations. The CAR awarded the remaining palay deposit to Fernando and ordered petitioners to pay specific amounts.

ISSUE

The principal issue is whether the Supreme Court should directly review the CAR’s decision, given that the petitioners’ appeal raises mixed questions of law and fact requiring examination of evidence, such as the propriety of the accounting, the factual determinations on usury, transplanting expenses, fertilizer use, and the exact indebtedness of a tenant.

RULING

The Supreme Court, in a Resolution penned by Justice Paredes, declined to exercise direct appellate jurisdiction and ordered the case forwarded to the Court of Appeals. The legal logic is grounded on jurisdiction and the nature of the issues presented. The petitioners’ own assignment of errors conceded that the appeal involved “mixed questions of law and fact.” The Court emphasized that resolving the legal questions, such as the proper interpretation and application of Sections 17 and 56 of R.A. No. 1199 and Article 24 of the Civil Code regarding usury, would necessarily require a prior evaluation and determination of the underlying factual controversies. These factual issues include whether usury was committed, whether a proper liquidation of past harvests was made, who bore specific expenses, and the correct amount of a tenant’s debt.
Since the resolution of the case is contingent on a re-examination of the evidence, which is a function of an intermediate appellate court, and as the petition did not raise any question involving the jurisdiction of the CAR or the constitutionality of any provision of the agrarian law, the Supreme Court found no compelling reason to retain the case. Accordingly, pursuant to Section 156 of the newly enacted Agricultural Land Reform Code ( R.A. No. 3844 ), which provides for the transfer of cases not involving jurisdiction or constitutionality, the Court directed the Clerk of Court to forward the records to the Court of Appeals for proper disposition. The En Banc concurred.