Sabado

8. Ayala v. Castillo

AYALA LAND, INC. AND CAPITOL CITIFARMS, INC. v. SIMEONA CASTILLO, LORENZO
PERLAS, JESSIELYN CASTILLO, LUIS MAESA, ROLANDO BATIQUIN, AND BUKLURAN
MAGSASAKA NG TIBIG, AS REPRESENTED BY THEIR ATTORNEY-IN-FACT, SIMEONA
CASTILLO (2016)

DOCTRINE: Rule 131, Section 1 of the Rules of Court, places the burden of proof on the alleging
party to present evidence on the facts in issue necessary to establish the claim or defense.
FACTS: Capitol Citifarms, Inc. (CCFI) owned two parcels of land with a total area of 221.3048
hectares located in Cavite. The subject land was mortgaged in favor of one of its creditors, Manila
Banking Corporation (MBC). The mortgage was subsequently foreclosed.
On May 22, 1987, the bank was placed under receivership by the BSP and the latter ordered the
sale of the land which was bought by Ayala Land, Inc. (ALI). The land was converted from
agricultural to non-agricultural (which DAR disapproved of but was granted by the OP on appeal).
Even though the farmers received disturbance compensation, they still appealed to the CA on the
ground that the conversion was not proper because a Notice of Acquisition was already issued.
However, said notice was not offered in evidence nor attached to any pleadings of the parties.
The farmers also did not raise the issue while the case was still pending with the DAR and OP.
Despite this, the CA still ruled in favor of the farmers.
ISSUE: Whether the CA committed reversible error when it gave credence to a mere assertion
by the tenant-farmers, rather than to the policy evaluation made by the OP

RULING: YES. A Notice of Acquisition was never offered in evidence before the DAR and never
became part of the records even at the trial court level. Thus, its existence is not a fully established
fact for the purpose of serving as the sole basis the entire history of the policy decisions made by
the DAR and the OP were to be overturned.
Rule 131, Section 1 of the Rules of Court, places the burden of proof on the alleging party to
present evidence on the facts in issue necessary to establish the claim or defense.

It is simply not the role of the Court to apply the missing Notice of Acquisition in perpetuity. Even
the Dissent concedes that the records are bereft of any trace of the Notice of Acquisition. This is
not a case of a feudal landowner unjustly enriched by the hard work of a long-suffering tenant.
ALI is in the precarious position of having been that third-party buyer that offered the terms and
conditions most helpful to, ultimately, the BSP. Prior to that acquisition, there was absolutely no
relationship between ALI and the farmers. Respondents, on the other hand, are residents who
have not yet established any claim — let alone substantial rights — over the land. On the contrary,
what has been duly established is that they have received disturbance compensation.

It is well established that issues raised for the first time on appeal and not raised in the
proceedings in the lower court are barred by estoppel. Points of law, theories, issues, and
arguments not brought to the attention of the trial court ought not to be considered by a reviewing
court, as these cannot be raised for the first time on appeal. To consider the alleged facts and
arguments belatedly raised would amount to trampling on the basic principles of fair play, justice,
and due process. More important, if these matters had been raised earlier, they could have been
seriously examined by the administrative agency concerned.
DISPOSITIVE: The MR is DENIED.