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GR No. 186366

2013-07-03

HEIRS OF JOSE FERNANDO v. REYNALDO DE BELEN

PEREZ, J.

Jurisprudence has it that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[20] As held in the case of Solmayor v. Arroyo,[21] it is not the function of this Court to analyze and weigh evidence all over again. This is premised on the presumed thorough appreciation of the facts by the lower courts. Such that, when the trial court and the appellate court, as in this case, reached opposite conclusions, a review of the facts may be done. There is a permissible scope of judicial review on the factual findings of the lower courts as crystallized in Treñas v. People of the Philippines,[22] where the Court cited contradictory findings of the Court of Appeals and the trial court as one of the instances where the resolution of the petition requires a review of the factual findings of the lower courts and the evidence upon which they are based.

GR No. 188299

2013-01-23

HEIRS OF LUIS A. LUNA v. RUBEN S. AFABLE

PEREZ, J.

It is well settled that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[36] This Court, in numerous instances, has had occasion to explain that it is not its function to analyze or weigh evidence all over again.[37] As a rule, the Court respects the factual findings of the CA and of quasi-judicial agencies like the DAR, giving them a certain measure of finality.[38] There are, however, recognized exceptions to this rule, one of which is when the findings of fact are conflicting.

GR No. 169913

2011-06-08

HEIRS OF DR. JOSE DELESTE v. LAND BANK OF PHILIPPINES

VELASCO JR., J.

It is undeniable that the local government has the power to reclassify agricultural into non-agricultural lands. In Pasong Bayabas Farmers Association, Inc. v. CA,[45] this Court held that pursuant to Sec. 3 of Republic Act No. (RA) 2264, amending the Local Government Code, municipal and/or city councils are empowered to "adopt zoning and subdivision ordinances or regulations in consultation with the National Planning Commission." It was also emphasized therein that "[t]he power of the local government to convert or reclassify lands [from agricultural to non-agricultural lands prior to the passage of RA 6657] is not subject to the approval of the [DAR]."[46]

GR No. 149548

2009-12-04

ROXAS v. DAMBA-NFSW

CARPIO MORALES, J.

In the above-cited case of Roxas & Co. v. CA,[9] the Court made it clear that the "power to determine whether Haciendas Palico, Banilad and Caylaway are non-agricultural, hence, exempt from the coverage of the [Comprehensive Agrarian Reform Law] lies with the [Department of Agrarian Reform], not with this Court."[10] The DAR, an administrative body of special competence, denied, by Order of October 22, 2001, the application for CARP exemption of Roxas & Co., it finding that PP 1520 did not automatically reclassify all the lands in the affected municipalities from their original uses. It appears that the PTA had not yet, at that time, identified the "specific geographic areas" for tourism development and had no pending tourism development projects in the areas. Further, report from the Center for Land Use Policy Planning and Implementation (CLUPPI) indicated that the areas were planted with sugar cane and other crops.[11]

GR No. 149548

2009-12-04

ROXAS v. DAMBA-NFSW

CARPIO MORALES, J.

In Pasong Bayabas Farmers Farmers Association, Inc. v. Court of Appeals,[91] the Court affirmed the authority of the municipal council to issue a zoning classification and to reclassify a property from agricultural to residential, as approved by the HSRC (now the HLURB). Section 3 of Republic Act No. 2264, amending the Local Government Code, specifically empowered municipal and/or city councils, in consultation with the National Planning Commission, to adopt zoning and subdivision ordinances or regulations.

GR No. 172400

2009-06-23

ZOSIMO OCTAVIO v. ENRICO R. PEROVANO

QUISUMBING, J.

However, whether or not petitioners are duly installed farmer-beneficiaries is a finding of fact. It is well-settled that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised. We have time and again ruled that the factual findings of fact by administrative agencies are generally accorded great respect, if not finality, by the courts because of the special knowledge and expertise of administrative departments over matters falling under their jurisdiction.[32] As held by this Court in Sta. Rosa Realty v. Court of Appeals, et al.,[33] the identification of farmer-beneficiaries is best left to the discretion of the Secretary of Agrarian Reform, through its authorized offices, as this is a matter involving strictly the administrative implementation of the CARP, and unless the Court finds that there was grave abuse of discretion committed by the agency involved, which the Court finds absent in this case, it will not substitute its judgment to that of the agency's.[34]

GR No. 168394

2008-10-06

AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. LORETO G. NICOLAS

REYES, R.T., J.

The Natalia ruling was reiterated in Pasong Bayabas Farmers Association, Inc. v. Court of Appeals,[37] Junio v. Garilao,[38] and De Guzman v. Court of Appeals.[39]

GR No. 155544

2007-08-24

MARINO ESCARIZ* Y DE LOS SANTOS v. GENARO D. REVILLEZA

SANDOVAL-GUTIERREZ, J.

A tenancy relationship cannot be presumed.[3] There must be evidence to support and prove the allegation that a tenancy relationship exists between petitioner and respondent. In Pasong Bayabas Farmers Association, Inc. v. Court of Appeals,[4] we held that the elements of a tenancy relationship are: (1) The parties are the landowner and the tenant or agricultural lessee;

GR NO. 166901

2006-10-27

ASIAN TERMINALS v. HELEN BAUTISTA-RICAFORT

CALLEJO, SR., J.

In fine, the initial orders of the RTC granting the issuance of the writ of replevin and its implementation are void.[37] While it is true that the District Collector of Customs allowed the release of the vehicles and the transfer thereof to the custody of the RTC upon the payment by the private respondents of the required taxes, duties and charges, he did not thereby lose jurisdiction over the vehicles; neither did it vest jurisdiction on the RTC to take cognizance of and assume jurisdiction over the petition for replevin. As very well explained by the Office of the Solicitor General, the District Collector of Customs agreed to transfer the vehicles to the custody of the RTC since the latter had ordered the arrest of those who would obstruct the implementation of the writ. The District Collector of Customs had yet to resolve whether to order the vehicles forfeited in favor of the government, in light of the opinion of the Secretary of Justice that, under RA No. 8506, the importation was illegal.

GR NO. 156965

2006-10-12

FROILAN DE GUZMAN v. CA

TINGA, J.

In Natalia Realty, Inc. vs. Department of Agrarian Reform,[11] it was held that lands not devoted to agricultural activity are outside the coverage of CARL including lands previously converted to non-agricultural uses prior to the effectivity of CARL by government agencies other than the DAR. This rule has been reiterated in a number of subsequent cases. Despite claims that the areas have been devoted for agricultural production, the Court has upheld the "non-agricultural" classification made by the NHA over housing and resettlements projects,[12] zoning ordinances passed by local government units classifying residential areas,[13] and certifications over watershed areas issued by the Department of Environment and Natural Resources (DENR).[14]

	GR No. 186366 2013-07-03	HEIRS OF JOSE FERNANDO v. REYNALDO DE BELEN PEREZ, J.
Jurisprudence has it that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[20] As held in the case of Solmayor v. Arroyo,[21] it is not the function of this Court to analyze and weigh evidence all over again. This is premised on the presumed thorough appreciation of the facts by the lower courts. Such that, when the trial court and the appellate court, as in this case, reached opposite conclusions, a review of the facts may be done. There is a permissible scope of judicial review on the factual findings of the lower courts as crystallized in Treñas v. People of the Philippines,[22] where the Court cited contradictory findings of the Court of Appeals and the trial court as one of the instances where the resolution of the petition requires a review of the factual findings of the lower courts and the evidence upon which they are based.
	GR No. 188299 2013-01-23	HEIRS OF LUIS A. LUNA v. RUBEN S. AFABLE PEREZ, J.
It is well settled that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[36] This Court, in numerous instances, has had occasion to explain that it is not its function to analyze or weigh evidence all over again.[37] As a rule, the Court respects the factual findings of the CA and of quasi-judicial agencies like the DAR, giving them a certain measure of finality.[38] There are, however, recognized exceptions to this rule, one of which is when the findings of fact are conflicting.
	GR No. 169913 2011-06-08	HEIRS OF DR. JOSE DELESTE v. LAND BANK OF PHILIPPINES VELASCO JR., J.
It is undeniable that the local government has the power to reclassify agricultural into non-agricultural lands. In Pasong Bayabas Farmers Association, Inc. v. CA,[45] this Court held that pursuant to Sec. 3 of Republic Act No. (RA) 2264, amending the Local Government Code, municipal and/or city councils are empowered to "adopt zoning and subdivision ordinances or regulations in consultation with the National Planning Commission." It was also emphasized therein that "[t]he power of the local government to convert or reclassify lands [from agricultural to non-agricultural lands prior to the passage of RA 6657] is not subject to the approval of the [DAR]."[46]
	GR No. 149548 2009-12-04	ROXAS v. DAMBA-NFSW CARPIO MORALES, J.
In the above-cited case of Roxas & Co. v. CA,[9] the Court made it clear that the "power to determine whether Haciendas Palico, Banilad and Caylaway are non-agricultural, hence, exempt from the coverage of the [Comprehensive Agrarian Reform Law] lies with the [Department of Agrarian Reform], not with this Court."[10] The DAR, an administrative body of special competence, denied, by Order of October 22, 2001, the application for CARP exemption of Roxas & Co., it finding that PP 1520 did not automatically reclassify all the lands in the affected municipalities from their original uses. It appears that the PTA had not yet, at that time, identified the "specific geographic areas" for tourism development and had no pending tourism development projects in the areas. Further, report from the Center for Land Use Policy Planning and Implementation (CLUPPI) indicated that the areas were planted with sugar cane and other crops.[11]
	GR No. 149548 2009-12-04	ROXAS v. DAMBA-NFSW CARPIO MORALES, J.
In Pasong Bayabas Farmers Farmers Association, Inc. v. Court of Appeals,[91] the Court affirmed the authority of the municipal council to issue a zoning classification and to reclassify a property from agricultural to residential, as approved by the HSRC (now the HLURB). Section 3 of Republic Act No. 2264, amending the Local Government Code, specifically empowered municipal and/or city councils, in consultation with the National Planning Commission, to adopt zoning and subdivision ordinances or regulations.
	GR No. 172400 2009-06-23	ZOSIMO OCTAVIO v. ENRICO R. PEROVANO QUISUMBING, J.
However, whether or not petitioners are duly installed farmer-beneficiaries is a finding of fact. It is well-settled that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised. We have time and again ruled that the factual findings of fact by administrative agencies are generally accorded great respect, if not finality, by the courts because of the special knowledge and expertise of administrative departments over matters falling under their jurisdiction.[32] As held by this Court in Sta. Rosa Realty v. Court of Appeals, et al.,[33] the identification of farmer-beneficiaries is best left to the discretion of the Secretary of Agrarian Reform, through its authorized offices, as this is a matter involving strictly the administrative implementation of the CARP, and unless the Court finds that there was grave abuse of discretion committed by the agency involved, which the Court finds absent in this case, it will not substitute its judgment to that of the agency's.[34]
	GR No. 168394 2008-10-06	AGRARIAN REFORM BENEFICIARIES ASSOCIATION v. LORETO G. NICOLAS REYES, R.T., J.
The Natalia ruling was reiterated in Pasong Bayabas Farmers Association, Inc. v. Court of Appeals,[37] Junio v. Garilao,[38] and De Guzman v. Court of Appeals.[39]
	GR No. 155544 2007-08-24	MARINO ESCARIZ* Y DE LOS SANTOS v. GENARO D. REVILLEZA SANDOVAL-GUTIERREZ, J.
A tenancy relationship cannot be presumed.[3] There must be evidence to support and prove the allegation that a tenancy relationship exists between petitioner and respondent. In Pasong Bayabas Farmers Association, Inc. v. Court of Appeals,[4] we held that the elements of a tenancy relationship are: (1) The parties are the landowner and the tenant or agricultural lessee;
	GR NO. 166901 2006-10-27	ASIAN TERMINALS v. HELEN BAUTISTA-RICAFORT CALLEJO, SR., J.
In fine, the initial orders of the RTC granting the issuance of the writ of replevin and its implementation are void.[37] While it is true that the District Collector of Customs allowed the release of the vehicles and the transfer thereof to the custody of the RTC upon the payment by the private respondents of the required taxes, duties and charges, he did not thereby lose jurisdiction over the vehicles; neither did it vest jurisdiction on the RTC to take cognizance of and assume jurisdiction over the petition for replevin. As very well explained by the Office of the Solicitor General, the District Collector of Customs agreed to transfer the vehicles to the custody of the RTC since the latter had ordered the arrest of those who would obstruct the implementation of the writ. The District Collector of Customs had yet to resolve whether to order the vehicles forfeited in favor of the government, in light of the opinion of the Secretary of Justice that, under RA No. 8506, the importation was illegal.
	GR NO. 156965 2006-10-12	FROILAN DE GUZMAN v. CA TINGA, J.
In Natalia Realty, Inc. vs. Department of Agrarian Reform,[11] it was held that lands not devoted to agricultural activity are outside the coverage of CARL including lands previously converted to non-agricultural uses prior to the effectivity of CARL by government agencies other than the DAR. This rule has been reiterated in a number of subsequent cases. Despite claims that the areas have been devoted for agricultural production, the Court has upheld the "non-agricultural" classification made by the NHA over housing and resettlements projects,[12] zoning ordinances passed by local government units classifying residential areas,[13] and certifications over watershed areas issued by the Department of Environment and Natural Resources (DENR).[14]

PASONG BAYABAS FARMERS ASSOCIATION v. CA