This case has been cited 1 times or more.
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2004-09-13 |
PANGANIBAN, J. |
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| Not binding on the courts is the Certification issued by the municipal agrarian reform officer of San Rafael, Bulacan, that respondent is "NOT a bonafide tenant of a parcel of land registered in the name of EUGENIO BAUTISTA, et al."[31] In a given locality, merely preliminary or provisional are the certifications or findings of the secretary of agrarian reform (or of an authorized representative) concerning the presence or the absence of a tenancy relationship between the contending parties; hence, such certifications do not bind the judiciary.[32] Moreover, in this case the CA found the Certification to have been issued without any prior investigation.[33] | |||||