OSMUNDO MEDINA, ROSARIO BANZUELA, NATIVIDAD GATCHALIAN, ANTONIO REYES, DAMIAN MARABE, ANGELITO ADOLFO, VIRGILIO ABALARAO, ANTONIA GONZALES, DANILO MARIANO, GAUDENCIO MARIANO, PABLO COROT, AVELINO BORON, ANTONIO TORCUATO, JULIAN TORCUATO, JR., GRACIANO ILAGAN, DEMOCRITO REAL, ADELAIDA ADOLFO, PEDRO…
- G.R. Number: G.R. No. 75450
- Promulgated: 1990-11-08
- Ponente: Bidin, J.
Doctrine
A Rule 45 petition to the Supreme Court is limited principally to questions of law; findings of fact by the Court of Appeals are binding except in established exceptions which do not obtain here.
Where facts remain unproven and are still subject to litigation, the Supreme Court will not substitute its factual findings for those of the Court of Appeals; Cunanan applies only when facts are admittedly proven.
Occupants whose possession of property was under litigation prior to executive proclamations or resolutions are not covered by those instruments' favorable provisions unless a court order resolves the litigation in their favor.
Facts
Petitioners sought certiorari under Rule 45 to review the Court of Appeals' 26 June 1986 decision dismissing their petition for prohibition and lifting a previously issued TRO. (dispositive quoted in CA decision).
The controversy concerns petitioners' status as occupants of PNR land: whether they are legitimate (bona fide) tenants entitled to benefits under PD 1517, Section 6, or are squatters who built near railroad tracks.
The land is in an area proclaimed for priority development and petitioners have occupied the premises for more than ten years, but their possession was under litigation prior to certain executive issuances.
Issues
Whether the petition for certiorari under Rule 45 properly raises questions of law only, or may impugn factual findings of the Court of Appeals concerning petitioners' tenancy status.
Whether petitioners are bona fide tenants of PNR entitled to benefits under Section 6, PD 1517, given that their possession was under litigation before issuing authorities.
Ruling
The Court affirmed the Court of Appeals' dismissal, holding Rule 45 petitions are generally limited to questions of law; Cunanan is inapplicable because facts here are not yet proven. The petition is denied except as modified regarding demolition authority.
The Court held petitioners cannot avail themselves of PD 1517 benefits (e.g., right of first refusal) because they are not bona fide tenants despite long occupation and the land's priority-development status.
Modification: respondents are without authority to demolish the houses of petitioners Medina, Gatchalian and Banzuela for being outside respondents' territorial jurisdiction; otherwise the petition for certiorari is denied.
Keywords
G.R. No. 75450, petition for prohibition, Presidential Decree No. 1517, urban land reform, Letter of Instruction No. 19, question of law, question of fact, Rules of Court, Rule 45, petition for certiorari, findings of fact, appreciation of evidence, grave abuse of discretion, Cunanan v. Lazatin (74 Phil. 719 [1944]), Sotto v. Teves (86 SCRA 154 [1978]), Manlapaz v. CA, 147 SCRA 236 [1987], Knecht v. CA, 158 SCRA 80 [1988], Nicolas et al., v. CA, 154 SCRA 635 [1987], Tiongco v. de la Merced, 58 SCRA 89 [1974], appeals