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Edwin N. Mendame Jr.

Digests Batch 1 3D Bonifacio

Evidence Judge

Reyes vs. Court of Appeals

Facts

Juan Mendoza. Father of defendant Olympio Mendoza owned a parcel of land in which the Julian dela Cruz and his family were living in as tenants and cultivators of palay. When Julian died, his wife succeeded him as the tenant of the lots in question.

Defendant, in conspiracy with other defendants allegedly prevented Eufrocinas daughter and her workers through force and intimidation from entering and working inside such premises and upon the filing of the case refused to leave the premises of the lots therefore violating their tenancy rights. They prayed for recovery of possession and damages with a writ of mandatory injunction.

Defendants raised abandonment, sublease and mortgage of the farmlots without authority as defense. They asked for actual and exemplary damages.

Issue

What kind of evidence is used in agrarian cases

Held/Ratio

Only substantial evidence is required to be used in agrarian cases. This states that it does not necessarily import preponderant evidence as is required in a civil case. It is defined to be such relevant evidence as a reasonable mind might accept as adequate to support a conclusion and its absence is not shown by stressing that there is contrary evidence on record, direct or circumstantial, for the appellate court cannot substitute its own judgment or criteria for that of the trial court in determining wherein lies the weight of the evidence entitled to belief.

The trial courts finding on the participation of the other defendants in threatening and forcing the tenants away is strengthened by the fact that they knew Olympio personally and were even asked by him to cultivate the land.

In the case at bar, the trial court did not err in considering the affidavits of Eufrocina and Tecson even though they did not go through cross-examination. Section 16 of P.D. 946 provides that the Rules of Court shall not be applicable in agrarian cases even in a suppletory character.

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