GR L 77090; (September, 1988) (Digest)
G.R. No. L-77090 September 16, 1988
DIOSCORD ESPADERA and LICERIA ESPADERA, petitioners, vs. THE HONORABLE COURT OF APPEALS, CIRIACA GEPAYO and AMBROCIO GEPAYO, respondents.
FACTS
Anulina Vda. de Bogacki purchased a property in 1954, using P800 belonging to her minor daughter Emma (whose guardian she was) and her own funds. She installed her sister, respondent Ciriaca Gepayo, as a tenant. In 1962, Anulina reconveyed the property to Emma upon demand. Emma later sold the land to petitioners Dioscord and Liceria Espadera in 1978. The petitioners subsequently fenced the property, excluding the respondents.
The respondents, Ciriaca and Ambrocio Gepayo, filed an action for reinstatement and damages, claiming to be agricultural tenants since 1954. The Regional Trial Court dismissed the complaint. On appeal, the Court of Appeals reversed the trial court, declaring the respondents as bona fide tenants/lessees entitled to reinstatement and awarding them damages. The petitioners then elevated the case to the Supreme Court via this petition for review.
ISSUE
The core issue is whether the petitioners can successfully challenge the tenancy relationship by raising, for the first time on appeal to the Supreme Court, a question regarding the identity of the property subject of the tenancy claim.
RULING
The Supreme Court denied the petition. The Court held that the factual findings of the Court of Appeals, which established the existence of a tenancy relationship between the parties, are conclusive and binding. A petition for review under Rule 45 of the Rules of Court is limited to questions of law; factual issues cannot be re-examined.
The petitioners’ new argument—that the property they bought from Emma was not the same property tenanted by the respondents due to a discrepancy in area—was deemed impermissible. The Court found that the deed of sale to Anulina explicitly conveyed only a one-half undivided share in the larger parcel, clearly explaining the area difference. Crucially, this issue of identity was never raised in the proceedings before the trial court or the Court of Appeals. Applying the well-settled rule, a party cannot raise an issue for the first time on appeal, especially at the stage of a Supreme Court review, when it was not presented in the lower tribunals. The failure to raise it earlier precludes its consideration. Thus, the Court affirmed the appellate court’s decision based on the established tenancy facts and the procedural bar against the new argument.