G.R. No. L-39767 March 31, 1987
LORENZO HERNANDEZ, petitioner, vs. THE COURT OF APPEALS and PEDRO DAGLI, respondents.

FACTS

Petitioner Lorenzo Hernandez owns a five-hectare coconut plantation in Quezon. Private respondent Pedro Dagli worked on the land and resided in a converted copra kiln on the premises. In 1971, Hernandez sought to evict Dagli to reconvert the dwelling into a kiln. Dagli responded by filing an action in the Court of Agrarian Relations to enforce security of tenure, claiming he was an agricultural tenant. Hernandez contested this, asserting Dagli was merely a hired laborer permitted to live and work on the plantation. The agrarian court ruled in favor of Hernandez, declaring Dagli was not a tenant and ordering him to vacate, while awarding him compensation for planted trees and releasing harvest proceeds to Hernandez.
Dagli appealed to the Court of Appeals. He assigned errors, including the agrarian court’s finding on tenancy status, the ejectment order, and the release of harvest proceeds to Hernandez without a share for Dagli. The appellate court reversed the decision, finding Dagli to be a tenant based on the nature of his work, his residence on the land, and a perceived sharing agreement. It ordered his maintenance on the land, reimbursement of his share of harvests, and an accounting of future proceeds. Hernandez’s motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in reversing the agrarian court’s factual finding that Dagli was a hired laborer and not a tenant, thereby raising a question of law reviewable by certiorari.

RULING

The Supreme Court denied the petition, upholding the Court of Appeals’ decision. The Court clarified the distinction between questions of law and fact for purposes of review. A question of law exists when the doubt concerns what the law is on a given state of facts, while a question of fact exists when the doubt concerns the truth or falsehood of alleged facts. A conclusion drawn from undisputed facts raises a question of law; otherwise, it is a question of fact.
In this case, the material allegations of the parties were in conflict. The Court of Appeals made its own evaluation of the evidence, including the kind of work performed, Dagli’s residence on the land, the historical tenancy of his parents, and the logical inference that a family man performing all stages of cultivation would not accept a measly wage if a sharing arrangement were possible. These were factual determinations. The Supreme Court found no compelling reason to disturb these findings, as they were supported by the record. The petition, essentially challenging factual conclusions, presented no reviewable question of law. Consequently, the appellate court’s ruling declaring Dagli a tenant entitled to security of tenure was affirmed.