ERLINDO CASANAYAN AND LOLITA BECIRA, PETITIONERS, VS. THE HONORABLE COURT OF APPEALS AND MIGUELA ANDRADE, RESPONDENTS.

Casanayan versus Court of Appeals

The Case

This is a petition for review brought by Erlindo Casanayan and Lolita Becira against the Court of Appeals and Miguela Andrade. The action below was one for recovery of possession of a parcel of land with damages. Miguela claimed the land as the widow and successor of Pascual Andrade, a settler-assignee under the National Resettlement and Rehabilitation Administration. The Casanayans claimed it as the long-time occupants and cultivators, through their father Remigio and then in their own right. The case matters because it is the Supreme Court's classic statement on when it will disturb the factual findings of the Court of Appeals, and on the weight to be given to official certifications and to administrative findings of the Presidential Action Committee on Land Problems.

Procedural History

Miguela Andrade filed the action for recovery of possession with damages before the Regional Trial Court of Isulan, Sultan Kudarat. After hearing, the trial court dismissed the complaint, finding the plaintiff's evidence insufficient and finding that she had failed to exhaust administrative remedies. Miguela appealed. The Court of Appeals reversed the trial court and rendered judgment in her favor, declaring that she had the better right of possession and ordering the Casanayans to vacate the portion of the land they held and to surrender it to her, with no damages and no costs. The Casanayans then came to the Supreme Court by petition for review under Rule 45 of the Rules of Court, raising only questions of law.

Facts

Pascual Andrade was the settler-assignee of a lot in Bambad, Isulan, Sultan Kudarat, within a survey identified as Pls-208-D-13, containing five hectares, as shown by a certificate of the National Resettlement and Rehabilitation Administration dated February 1956. He had filed a homestead application with the defunct LASEDECO, but no patent had been issued. He died in 1956. In November 1968, his widow Miguela filed her own homestead application in her own name to supersede her husband's application. Sometime in 1968, according to her, the Casanayans entered and occupied the eastern two and one-half hectares by stealth, strategy, force and intimidation. She protested to the District Land Officer, who sent the Casanayans a notice advising them to vacate.

The Casanayans answered that the land had first been occupied and cultivated by their father, Remigio Casanayan, from 1952 until he was murdered, and that the brothers continued his occupation and cultivation as owners. Erlindo had filed his own homestead application for the lot as early as 1965. They also pointed to an earlier administrative case that Miguela had brought before the Presidential Action Committee on Land Problems, which had found that she was not entitled to possession and had dismissed her complaint.

The trial court dismissed Miguela's complaint. The Court of Appeals reversed, relying principally on the NARRA certificate and on the letter of the Acting District Land Officer, and concluded that Miguela and her husband before her were the lawful possessors. The Casanayans challenged those exhibits as hearsay and as insufficient, and insisted that the administrative findings had been ignored.

Issues

• Whether or not the Court of Appeals erred in giving weight and credence to the NARRA certificate and the District Land Officer's letter.
• Whether or not the Court of Appeals erred in disregarding the factual findings of the Presidential Action Committee on Land Problems.
• Whether or not the evidence relied upon by the Court of Appeals was sufficient to establish Miguela's right of possession.

Applicable Provisions

Section 44 of Rule 130 of the Rules of Court, on entries in official records, provides:

Entries in official records made in the performance of his duty by a public officer of the Philippines, or by a person in the performance of a duty specially enjoined by law, are prima facie evidence of the facts stated therein.

This is the provision under which the NARRA certificate and the District Land Officer's letter were offered, and it fixes their weight as merely prima facie evidence of the facts stated.

Ruling

On the first issue, the Court held that the petitioners could no longer challenge the admission of the exhibits, because an objection to the admission of an exhibit must be made at the time it is offered, and the record showed that when the trial judge required written objections to the plaintiff's offer of exhibits, the petitioners never submitted any. A continuing objection noted during the narration of a witness was not sufficient. But even assuming the exhibits were admissible, the Court held they were not sufficient to establish Miguela's claim. The mere certification that Pascual was a settler-assignee did not prove that he was actually in possession, nor did it show that the certifying officer personally knew that fact or received it through official information. The District Land Officer's conclusion appeared to have been made ex parte, after which the petitioners were simply asked to vacate. At any rate, the exhibits were only prima facie evidence of the facts stated, and that prima facie showing had been disproved by the petitioners.

On the second issue, the Court held that the Court of Appeals should have considered the factual findings of the Presidential Action Committee on Land Problems, which had been designated by Presidential Decree 832 to investigate and rule upon land problems and whose decisions have the force and effect of a regular administrative resolution. Such findings must be received with respect by the courts and are binding in the absence of proof that they were arbitrarily reached, and no such proof was shown. The Committee had found that Miguela filed her homestead application in 1968 while Erlindo filed his in 1965, that the NARRA certificate referred only to a portion of the lot, and that the land was public land long occupied and cultivated by the Casanayan brothers.

On the third issue, the Court held that the Court of Appeals failed to consider the substantial evidence of the petitioners' possession, and noted the undertaking of June 1957 between Miguela and Remigio Casanayan, with the intervention of the Bambad Settlers Association, which showed that she and her husband had not been in possession since 1951 as she claimed. The Court concluded that Miguela had failed to prove her possession and that the evidence relied upon by the Court of Appeals was insufficient to sustain her claim.

Doctrine

First, in a petition for review under Rule 45, only questions of law may be raised, and the factual findings of the Court of Appeals are generally conclusive upon the Supreme Court, except in the exceptional circumstances the Court enumerated, among them that the findings of the appellate court are contrary to those of the trial court. Second, entries in official records are only prima facie evidence of the facts stated, and a certification that a person is a settler-assignee does not by itself prove actual possession. Third, the factual findings of the Presidential Action Committee on Land Problems, rendered after full hearing, carry the force and effect of a regular administrative resolution and must be respected and are binding absent proof that they were arbitrarily reached.

Disposition

The Court reversed the decision of the Court of Appeals and declared that, pending determination by the Bureau of Lands of the conflicting homestead applications, the petitioners have the better right of possession of the land, with costs against the private respondent.

Remember This

Memorize this line: official certifications are only prima facie evidence, and the factual findings of the Presidential Action Committee on Land Problems bind the courts absent arbitrariness. Examiners use this case on the conclusiveness of the Court of Appeals' factual findings and the exceptions thereto, and on the weight of administrative findings in land disputes.