G.R. No. 92103 - Teologo vs. Civil Service Commission

Banal na Pag-aaral, Inc. (the petitioner) initially sought the registration of a parcel of land.
The Court of Appeals (CA) dismissed its application on the ground that the petitioner failed to prove the land was alienable and disposable.

After the dismissal, the petitioner filed a motion for reconsideration.
Along with its motion, the petitioner submitted a Certification issued by the Department of Environment and Natural Resources declaring the subject land alienable and disposable.
The Office of the Solicitor General did not object to this belated submission of evidence.

The CA, on January 8, 2010, through its Amended Decision, reversed its initial ruling and allowed the registration of the subject land.
In rendering its decisions, the CA invoked Section 9 of Batas Blg. 129 (as amended by R.A. No. 7902) which grants it the power to receive evidence and perform acts necessary to resolve factual issues.
However, the CA’s authority to admit new evidence on appeal is limited and typically available only when the court grants a new trial.
The CA’s unqualified admission of the Certification was contrary to the general rule that evidence not formally offered should not be considered.

The Supreme Court, in the interest of justice and for the most meritorious of reasons, allowed the late submission of the certification in this petition.
The Court required that the parties be given the opportunity to verify the authenticity and proper execution of the document.

The Supreme Court remanded the case back to the Court of Appeals.
The CA is directed to further determine the authenticity and due execution of the submitted certification.
The CA is also directed to hear and receive evidence from the parties and to report back its resolution to the Supreme Court for appropriate action.

Whether the CA properly exercised its power under Section 9 of Batas Blg. 129 in unconditionally admitting evidence that was not formally presented during the initial proceedings.
Whether the belated submission of a Certification by the petitioner should be considered and verified despite the general rule against admitting such evidence on appeal.

Whether an appellate court may perform acts similar to those of a trial court (i.e., receiving new evidence) when the issue is on appeal and when a new trial has not been expressly granted.

Whether the interests of justice justify the admittance and verification of evidence even if such evidence was submitted belatedly in violation of the standard evidentiary rule.