Reyes v. CA – GR 96492, 26 November 1992

Facts:
Petitioner seeks the reversal of the decision of the Court of Appeals in affirming the decision of the agrarian court finding them violating the tenancy rights of the private respondents when they allegedly thru strong arms method, prevented the daughter of the private respondent and her workers to enter and work on the disputed land. The petitioner appealed the decision of the CA for accepting the affidavits of the witnesses of the private respondents and not subjecting them to a cross examination as prescribed by the Rules of court.

Issue:
Whether the trial court err when it did not apply Rules of Court in hearing Agrarian Cases?

Held:
No, Finally, the trial court did not err when it favorably considered the affidavits of Eufrocina and Efren Tecson although the affiants were not presented and subjected to cross-examination. Section 16 of P.D. No. 946 provides that the “Rules of Court shall not be applicable in agrarian cases even in a suppletory character.” The same provision states that “In the hearing, investigation and determination of any question or controversy, affidavits and counter-affidavits may be allowed and are admissible in evidence”.