G.R. No. 55318 - Malate vs. Court of Appeals

The Court of Appeals' role in agrarian cases is limited to assessing whether the findings of fact from the Court of Agrarian Relations are supported by substantial evidence.
Substantial evidence is defined as relevant evidence that a reasonable mind might accept as adequate to support a conclusion.
The appellate court cannot substitute its own findings of fact for those of the agrarian court if the latter's findings are supported by substantial evidence.

The original landowner was Feliciana Bautista, who instituted tenants on the landholding in 1939.
Petitioners Norberto and Benedicto Esguerra were instituted as tenants in 1961, with the consent of Feliciana Bautista, due to their father's old age.
The petitioners had a sharing agreement with the landowner, receiving 75% of the produce while the landowner received 25%.
After the death of Feliciana Bautista, the administration of the land passed to her sister, Matea Bautista, and later to private respondent Felino Gemanil.

In 1976, Felino Gemanil proposed to plant sugarcane on the land, offering the petitioners a 15% share of the gross harvest, which they accepted.
Gemanil failed to honor this agreement and refused to reinstate the petitioners as tenants, prompting them to file a complaint with the Court of Agrarian Relations.
The Court of Agrarian Relations ruled in favor of the petitioners, but this decision was reversed by the Court of Appeals.

Petitioners contended that the Court of Appeals erred in reversing the findings of the Court of Agrarian Relations, claiming violations of the rule on substantial evidence.
They argued that the appellate court misapprehended the evidence, particularly regarding tax declarations and witness testimonies.
Petitioners also claimed that the Court of Appeals incorrectly presumed that the absence of certain witnesses indicated unfavorable evidence against them.

The evidence presented by the petitioners was deemed clear and direct, corroborated by witness testimony.
The testimony of Felino Gemanil was found to be unreliable and inconsistent, undermining his claims against the petitioners'...continue reading