G.R. No. L-61129. January 31, 1985.
SPOUSES ESPIRIDION TERUÑEZ and MACARIA TERUÑEZ, petitioners, vs. HONORABLE INTERMEDIATE APPELLATE COURT and VIOLETO CAMAYRA, respondents.

FACTS

This case originated from a complaint filed by Violeto Camayra against the spouses Espiridion and Macaria Teruñez in the Court of Agrarian Relations in Iloilo City. Camayra prayed to be recognized as a share tenant on an agricultural land planted with coconuts, alleging that he was instituted as a tenant by Florentino Torreta, the father of Macaria Teruñez. The Agrarian Court dismissed the complaint, characterizing Camayra as a mere hired laborer and ordering him to pay attorney’s fees and litigation expenses to the Teruñez spouses.
On appeal, the then Court of Appeals (now the Intermediate Appellate Court) reversed the trial court’s decision. The appellate court declared Camayra a de jure share tenant of the Teruñez spouses, ordered his reinstatement, and awarded him nominal damages and litigation expenses. The Teruñez spouses subsequently filed this petition for review, assailing the appellate court’s reversal.

ISSUE

Whether the Supreme Court should review the factual findings of the Intermediate Appellate Court, which held that Violeto Camayra is a share tenant and not a mere hired laborer.

RULING

The Supreme Court dismissed the petition and affirmed the decision of the Intermediate Appellate Court. The Court held that the petition did not present any valid ground warranting the exercise of its discretionary power of review under Rule 45, Section 4 of the Rules of Court. The core issue—Camayra’s status as a tenant—was purely factual. The trial court had dismissed the complaint primarily because Camayra failed to present specific evidence on the gross and net produce of the land and the exact sharing arrangement during a certain period.
The appellate court, however, found this reasoning erroneous, as it ignored the preponderance of other evidence presented by Camayra that clearly established his tenancy relationship with the late Florentino Torreta. The appellate court extensively reviewed this evidence, leading to its factual conclusion. The Supreme Court emphasized that it is not a trier of facts and will not re-examine factual determinations of the Court of Appeals absent compelling reasons, such as a substantial departure from accepted judicial proceedings or a decision on a question of substance not in accord with law or applicable jurisprudence. No such exceptional circumstances were present in this case. Therefore, the factual findings of the Intermediate Appellate Court are final and binding.