G.R. No. L-8129 July 25, 1955
VALERIANO NICOLAS and SOCORRO SAN JOSE, petitioners, vs. THE HON. MODESTO CASTILLO, Judge of the Court of Industrial Relations and REYNALDO NAEL, respondents.

FACTS

Petitioners Valeriano Nicolas and Socorro San Jose entered into a tenancy contract with respondent Reynaldo Nael for the cultivation of an 8-hectare riceland during the 1950-51 agricultural year, with a sharing basis of 75% for the tenant and 25% for the landlords. In March 1951, Nael filed a complaint in the Justice of the Peace Court of Sipocot, Camarines Sur, to recover his share of 70 cavanes of palay allegedly harvested. Petitioners countered that due to Nael’s negligence, the harvest was only 76 cans (19 cavanes) and filed a counterclaim for damages. The case, being a tenancy dispute, was certified to the Court of Industrial Relations (CIR). Attorney Benedicto Bonifacio was commissioned by the CIR to receive evidence, but at the hearing, Nael did not appear, so petitioners presented evidence on their counterclaim. To give Nael an opportunity, the CIR set another hearing and designated the Justice of the Peace of Sipocot to receive evidence, with the evidence previously adduced before Commissioner Bonifacio remaining in the record. The case was eventually tried before Judge Vicente Tuason of Naga City. On May 31, 1954, the CIR rendered judgment, finding the harvest to be 76 cavanes and ordering petitioners to deliver Nael’s share. Petitioners filed a petition for review in the Supreme Court (G.R. No. L-7939), which was dismissed for raising factual questions. Subsequently, on August 30, 1954, petitioners filed this petition for certiorari under Rule 67, alleging that the CIR’s decision was based only on a portion of the evidence (specifically, the evidence before Judge Tuason) and not on the entirety of the record, including the evidence presented before Commissioner Bonifacio.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion by rendering a decision based only on a portion of the evidence on record, thereby justifying the issuance of a writ of certiorari to annul said decision.

RULING

The Supreme Court denied the petition for certiorari. The Court held that none of the grounds raised by petitioners sufficiently overcame the presumption that official duty had been performed and that the CIR considered the entirety of the evidence. The failure to mention the proceedings before Commissioner Bonifacio in the decision’s narration of facts did not prove the CIR was unaware of them, as the presiding judge who penned the decision was the same judge who commissioned Bonifacio, and the transcript before Judge Tuason contained references to those proceedings. The use of the word “uncontroverted” to describe Nael’s evidence was interpreted to mean “not sufficiently overcome” rather than “uncontradicted.” The physical condition of the records did not conclusively prove that the transcript of the first hearing was unavailable when the decision was rendered. Moreover, even assuming the CIR based its decision solely on the evidence before Judge Tuason, no prejudice was caused to petitioners because the evidence presented before Judge Tuason was substantially the same as that presented before Commissioner Bonifacio. Additionally, the Supreme Court emphasized the settled doctrine that a writ of certiorari should be denied if the relief sought was obtainable in the original proceedings and no motion for reconsideration was filed to give the lower court an opportunity to correct its alleged errors. Since petitioners did not file a motion for reconsideration in the CIR, the writ was denied on this ground as well.