Facts:

The case involves petitioners Angeles Malate, Norberto Esguerra, and Benedicto Esguerra against respondents Honorable Court of Appeals and Felino Gemanil. The events leading to this case began in 1939 when Feliciana Bautista, the original owner of a landholding, instituted tenants Francisco Esguerra and Artemio Gonzales. In 1961, due to the old age of their father, Norberto and Benedicto Esguerra were instituted as tenants on the land with the consent of Bautista. Similarly, Angeles Malate was instituted as a tenant by Gonzales, also with Bautista's consent. The agreement established a 75-25 sharing basis in favor of the petitioners for the produce of the land, which was primarily used for planting pineapple, papaya, banana, and rice. The petitioners consistently delivered the landowner's share until Bautista's death, after which her sister Matea Bautista took over the administration, and the petitioners continued to fulfill their obligations.

In 1976, after Ma...

Facts:

1. Ownership and Tenancy History:

   • The landholding in question was originally owned by Feliciana Bautista, the mother of private respondent Felino Gemanil.
   • In 1939, Feliciana Bautista instituted Francisco Esguerra (father of petitioners Norberto and Benedicto Esguerra) and Artemio Gonzales (uncle of petitioner Angeles Malate) as tenants on the landholding.
   • In 1961, petitioners Norberto and Benedicto Esguerra were instituted as tenants by their father, with the consent of Feliciana Bautista, due to their father's old age. Similarly, Angeles Malate was instituted as a tenant by his uncle, Artemio Gonzales, with Feliciana Bautista's consent.
   • The landholding was cultivated with pineapple, papaya, banana, and rice, with a 75-25 sharing arrangement in favor of the tenants.

2. Change in Administration:

   • After Feliciana Bautista's death, her sister Matea Bautista took over the administration of the landholding, and the tenants continued to deliver the landowner's share.
   • In 1976, after Matea's death, private respondent Felino Gemanil proposed to petitioners that he would plant sugarcane on the landholding for three years and give them 15% of the gross harvest. Petitioners agreed, but Gemanil failed to fulfill his promise and refused to reinstate them as tenants.

3. Legal Proceedings:

   • Petitioners filed a complaint with the Court of Agrarian Relations, which ruled in their favor, ordering their reinstatement as tenants and awarding them damages.
   • On appeal, the Court of Appeals reversed the decision, finding that petitioners were not legitimate tenants.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Substantial Evidence Standard:

   • In agrarian cases, the appellate court's role is limited to determining whether the findings of fact of the agrarian court are supported by substantial evidence. Substantial evidence is defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
   • The Supreme Court found that the testimony of the petitioners, corroborated by witness Marianito Manalo, was clear, consistent, and credible, while the testimony of private respondent Felino Gemanil was unreliable and contradictory.

2. Presumption Against Suppressed Evidence:

   • The Court rejected the application of the presumption that suppressed evidence is unfavorable to the petitioners, as the petitioners' failure to present certain witnesses (Francisco Esguerra and Artemio Gonzales) did not undermine their case, given the substantial evidence already on record.

3. Finality of Agrarian Court's Findings:

   • The Supreme Court emphasized that where the findings of fact of the agrarian court are supported by substantial evidence, such findings are conclusive and binding on the appellate court. The appellate court cannot substitute its own findings of fact.

WHEREFORE, the decision of respondent Court of Appeals is hereby REVERSED and set aside, and the decision of the Court of Agrarian Relations is REINSTATED.
###