Quitoriano vs. DARAB

The Supreme Court does not have jurisdiction to review questions of fact in a Petition for Review on Certiorari under Rule 45; factual findings of quasi-judicial bodies such as the DARAB, when supported by substantial evidence and affirmed by the Court of Appeals, are accorded finality and conclusiveness, absent any of the recognized exceptions such as grave abuse of discretion, manifestly mistaken inference, or findings contrary to those of the trial court.

The case involves a dispute over ownership and possession of an agricultural lot covered by the Operation Land Transfer program under Presidential Decree No. 27. The controversy arose when the heirs of Nicolas Quitoriano claimed ownership over Lot 7733-B, which had been transferred by the heirs of Fermin Rabina to their tenant-farmer Eduardo Aglibot under the land reform program, resulting in the issuance of an emancipation patent and original certificate of title in Aglibot's name. The petitioners sought the cancellation of these titles, alleging fraud and claiming the land formed part of their inherited property.

• On July 21, 1989, the Heirs of Fermin Rabina, through Atty. Emiliano Rabina, conveyed Lots 7733-A (5,756 square meters) and 7733-B (2,801 square meters) to their tenant-farmer Eduardo Aglibot via two Deeds of Absolute Transfer under Presidential Decree No. 27, for which Aglibot paid a total of P6,000.
• Emancipation Patent Nos. 159570 and 151580 were issued, and Original Certificates of Title Nos. 1358 and 1183 were issued in 1991 to cover Lots 7733-A and 7733-B, respectively, in the name of Aglibot.
• Petitioners (heirs of Nicolas Quitoriano) claimed that Lot 7733-B (subject lot) formed part of their 110,886 square-meter property inherited from Nicolas Quitoriano, which they had possessed peacefully since the Second World War and allowed Severino Beniola to cultivate since 1958.
• On July 20, 1996, Aglibot allegedly took possession of the subject lot by force and intimidation from Beniola, prompting petitioners to file a complaint for forcible entry and a petition for cancellation of EP No. 151580 and OCT No. 1183.
• The Provincial Adjudicator found that DENR survey records showed Nicolas Quitoriano's property comprised only 103,849 square meters, excluding the subject lot, and that the subject lot belonged to the Rabina family.
• The Provincial Adjudicator ruled that the Deed of Absolute Transfer to Aglibot was valid, that Aglibot was a bona fide tenant, and that the MARO conducted a proper investigation including a public hearing before issuing the emancipation patent.

• The execution of the Deed of Absolute Transfer by Atty. Emiliano Rabina in favor of Aglibot was vitiated by fraud, as Aglibot misrepresented that the subject lot belonged to the Rabina family when it actually formed part of the Quitoriano property.
• Aglibot was not a bona fide tenant of the subject lot and was therefore not entitled to the emancipation patent and title under Presidential Decree No. 27.
• The subject lot forms part of the 110,886 square-meter property owned by Nicolas Quitoriano, as evidenced by tax declarations and official receipts for real property taxes dating back to 1951.
• The Municipal Agrarian Reform Office failed to conduct a thorough investigation to ascertain the true ownership of the subject lot before issuing the emancipation patent.

• The Deed of Absolute Transfer was valid and executed in accordance with law, with no competent evidence showing fraud or irregularity in its execution.
• Aglibot was a bona fide agricultural tenant entitled to the benefits of Presidential Decree No. 27, as established by the MARO investigation and public hearing conducted prior to the issuance of the emancipation patent.
• The subject lot was not part of the Quitoriano property but belonged to the Rabina family, as evidenced by DENR survey records showing the Quitoriano property comprised only 103,849 square meters.
• The presumption of regularity in the performance of official duty applies to the MARO's investigation and the issuance of the emancipation patent.

• Procedural:
  • Whether the Petition for Review on Certiorari may be entertained despite raising questions of fact regarding the existence of fraud and the location of the subject lot within petitioners' property.
• Substantive Issues:
  • Whether the subject lot forms part of the petitioners' property or belongs to the Rabina family.
  • Whether there was fraud in the execution of the Deed of Absolute Transfer that would invalidate the emancipation patent and title issued to Aglibot.
  • Whether respondent Aglibot is a bona fide agricultural tenant entitled to the benefits of Presidential Decree No. 27.

• Procedural:
  • The petition raises questions of fact regarding the existence of fraud and the determination of property boundaries, which require an examination of the probative value of the evidence presented; such questions are not reviewable under Rule 45.
  • The Supreme Court is not a trier of facts and does not analyze or weigh evidence; its jurisdiction is limited to reviewing and rectifying errors of law allegedly committed by lower courts.
  • None of the recognized exceptions to the finality of factual findings (such as grave abuse of discretion, manifestly mistaken inference, or findings grounded on speculation) are present in this case.
• Substantive:
  • The subject lot is not part of the petitioners' property; the Provincial Adjudicator correctly relied on DENR survey records showing the Quitoriano property comprised only 103,849 square meters, placing the subject lot outside petitioners' boundaries, and rejected petitioners' unaccredited sketch plan.
  • Fraud cannot be presumed and must be proven by clear and convincing evidence; petitioners failed to prove fraud as their evidence consisted only of the self-serving, uncorroborated testimony of Atty. Emiliano Rabina.
  • Aglibot is a bona fide agricultural tenant entitled to the emancipation patent under Presidential Decree No. 27, as established by the MARO investigation and public hearing, and affirmed by the Provincial Adjudicator and DARAB.
  • The presumption of regularity in the performance of official duty applies to the MARO's investigation and the issuance of the emancipation patent in the absence of evidence showing irregularity.

• Questions of Law vs. Questions of Fact — A question of law arises when the doubt or difference is as to what the law is on a certain state of facts; a question of fact arises when the doubt or difference is as to the truth or falsehood of alleged facts. The Supreme Court, in a petition for review on certiorari under Rule 45, is limited to questions of law and does not entertain questions of fact.
• Finality of Factual Findings of Quasi-Judicial Bodies — Findings of fact by quasi-judicial bodies which have acquired expertise because their jurisdiction is confined to specific matters (such as the DARAB) are accorded not only respect but even finality if they are supported by substantial evidence, even if not overwhelming or preponderant, provided there is no grave abuse of discretion.
• Presumption of Regularity in Performance of Official Duty — Under Section 3(m) of Rule 131 of the Rules of Court, official duty has been regularly performed is a disputable presumption. This applies to the investigation conducted by the Municipal Agrarian Reform Office and the issuance of emancipation patents.
• Fraud as Question of Fact — Fraud is a question of fact which must be alleged and proved at the level of the lower court by clear and convincing evidence; it cannot be presumed.

• "Fraud cannot be presumed and must be proven by clear and convincing evidence."
• "The Court is not a trier of facts."
• "It is not the function of this Court to analyze or weigh evidence."
• "There is a question of law in a given case when the doubt or difference arises as to what the law is on a certain state of facts; there is a question of fact when the doubt or difference arises as to the truth or the falsehood of alleged facts."
• "Findings of facts by quasi-judicial bodies which have acquired expertise because their jurisdiction is confined to specific matters, are accorded not only respect but even finality if they are supported by substantial evidence, even if not overwhelming or preponderant."

• Macawiwili Gold Mining and Development Co., Inc. v. Court of Appeals — Cited for the distinction between questions of law and questions of fact.
• Philippine American Life Insurance Company v. Court of Appeals — Cited for the rule that fraud is a question of fact which must be alleged and proved.
• The Manila Electric Company v. South Pacific Plastic Manufacturing Corporation — Cited for the rule that fraud must be proven by clear and convincing evidence.
• Zaragoza v. Nobleza — Cited for the rule that the Court is not a trier of facts and issues of fact may not be passed upon in a petition for review on certiorari.
• Microsoft Corporation v. Maxicorp, Inc. — Cited for the principle that it is not the function of the Supreme Court to analyze or weigh evidence.
• Cabatania v. Court of Appeals — Cited for the enumeration of exceptions to the rule that factual issues are not within the province of the Supreme Court.
• Joson v. Mendoza — Cited for the rule that in agrarian cases, the Court of Appeals' function is limited to determining whether DARAB findings are supported by substantial evidence, and if so, such findings are conclusive and binding.
• Reyes v. Reyes — Cited for the rule that the Court of Appeals cannot make its own findings of fact and substitute them for the DARAB's findings where there is no abuse of discretion.
• Corpuz v. Sps. Grospe — Cited for the rule that if factual findings of the Court of Appeals coincide with those of the DARAB, such findings are accorded respect and will not be disturbed.
• National Steel Corporation v. Court of Appeals — Cited for the rule on finality of factual findings of quasi-judicial bodies supported by substantial evidence.

• Presidential Decree No. 27 — The Operation Land Transfer program under which the Deed of Absolute Transfer was executed and the Emancipation Patent was issued in favor of Aglibot.
• Rule 45 of the Rules of Court — Governs petitions for review on certiorari to the Supreme Court, limited to questions of law.
• Rule 131, Section 3(m) of the Rules of Court — Provides for the disputable presumption that official duty has been regularly performed, applied to the MARO investigation and issuance of the emancipation patent.

• Ynares-Santiago, Austria-Martinez, Nachura, and Reyes, JJ. — Joined in the decision without issuing separate concurring opinions.