Lawyerly

GR No. 184355

2015-03-23

PERALTA, J.

As a rule, only questions of law may be raised in a petition for review under Rule 45 of the Rules of Court.[8] As such, we are not duty-bound to analyze and weigh all over again the evidence already considered in the proceedings below. The findings of facts by a trial court, when affirmed by the Court of Appeals, are binding on the Supreme Court.[9] This rule, however, is not without exceptions.[10] However, petitioner failed to show that his case falls under any of the exceptions.

GR No. 185666

2015-02-04

NIPPON EXPRESS CORP. v. CIR

PEREZ, J.

At the outset, in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[15] The Court is not a trier of facts and does not normally undertake the re-examination of the evidence presented by the contending parties during the trial of the case considering that the findings of facts of the (CTA) are conclusive and binding on the Court[16] and they carry even more weight when the (CTA En Banc) affirms the factual findings of the trial court.[17] However, this Court had recognized several exceptions to this rule,[18] including instances when the appellate court manifestly overlooked relevant facts not disputed by the parties, which, if properly considered, would probably justify a different conclusion.

GR No. 185432

2014-06-04

MIRAMAR FISH COMPANY v. CIR

PEREZ, J.

At the outset, this Court is not unaware that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[13] The Court is not a trier of facts and does not normally undertake the re-examination of the evidence presented by the contending parties during the trial of the case considering that the findings of facts of the [CTA] are conclusive and binding on the Court[14] and they carry even more weight when the [CTA En Banc] affirms the factual findings of the trial court.[15] However, this Court had recognized several exceptions to this rule,[16] including instances when the appellate court manifestly overlooked relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.

GR No. 169778

2014-03-12

CIR v. SILICON PHILIPPINES

PEREZ, J.

It is well settled that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[14] The Court is not a trier of facts and does not normally undertake the re-examination of the evidence presented by the contending parties during the trial of the case considering that the findings of facts of the CA are conclusive and binding on the Court[15] and they carry even more weight when the CA affirms the factual findings of the trial court.[16] However, the Court had recognized several exceptions to this rule, to wit: (1) when the findings are grounded entirely on speculation, surmises or conjectures; (2) when the inference made is manifestly mistaken, absurd or impossible; (3) when there is grave abuse of discretion; (4) when the judgment is based on a misapprehension of facts; (5) when the findings of facts are conflicting; (6) when in making its findings the CA went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (7) when the findings are contrary to the trial court; (8) when the findings are conclusions without citation of specific evidence on which they are based; (9) when the facts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondent; (10) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and (11) when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[17]

GR No. 195002

2012-01-25

HECTOR TREÑAS v. PEOPLE

SERENO, J.

(1) When the factual findings of the Court of Appeals and the trial court are contradictory; (2) When the conclusion is a finding grounded entirely on speculation, surmises or conjectures; (3) When the inference made by the Court of Appeals from its findings of fact is manifestly mistaken, absurd or impossible; (4) When there is grave abuse of discretion in the appreciation of facts; (5) When the appellate court, in making its findings, went beyond the issues of the case, and such findings are contrary to the admissions of both appellant and appellee; (6) When the judgment of the Court of Appeals is premised on misapprehension of facts; (7) When the Court of Appeals failed to notice certain relevant facts which, if properly considered, would justify a different conclusion; (8) When the findings of fact are themselves conflicting; (9) When the findings of fact are conclusions without citation of the specific evidence on which they are based; and (10) When the findings of fact of the Court of Appeals are premised on the absence of evidence but such findings are contradicted by the evidence on record.[14]

GR No. 132604

2002-03-06

VENANCIO SAMBAR v. DOING BUSINESS UNDER NAME

QUISUMBING, J.

We find that the first issue raised by petitioner is factual. The basic rule is that factual questions are beyond the province of this Court in a petition for review. Although there are exceptions to this rule, this case is not one of them.[5] Hence, we find no reason to disturb the findings of the Court of Appeals that Europress' use of the arcuate design was an infringement of the Levi's design.

GR No. 134741

2001-12-19

SPS. BENNY CALVO AND JOVITA S. CALVO v. SPS. BERNARDITO AND ANGELINA VERGARA AND SPS. ALEXBERTO AND BELIBETH BASALO

QUISUMBING, J.

In Reyes vs. Court of Appeals, G.R. No. 110207, 258 SCRA 651, 658 (1996), we distinguished between the two types of questions: there is a question of law when the doubt or difference arises as to what the law is pertaining to a certain state of facts, and there is a question of fact when the doubt arises as to the truth or falsity of alleged facts. Being a question of fact, it is beyond the office of this court in a petition for review under Rule 45 of the Revised Rules of Court, where only questions of law may be raised.[13] Although there are exceptions,[14] petitioners did not show that this is one of them. Additionally, petitioners, in raising the above issue, is in effect questioning the factual findings of the DARAB, contrary to the doctrine that findings of fact by administrative agencies are generally accorded great respect, if not finality by the courts because of the special knowledge and expertise over matters falling under their jurisdiction.[15] It must be stressed at this point that the DARAB has the jurisdiction on all agrarian disputes involving the implementation of agrarian laws, including PD 27.[16]

GR No. 124809

2001-12-19

PEOPLE v. ROBERTO SAUL

QUISUMBING, J.

Well-entrenched is the rule that one who invokes self-defense admits authorship of the killing, thus the burden shifts to that person to establish the justifying circumstance with clear and convincing evidence.[19] One who pleads it must rely on the strength of his own evidence and not on the weakness of that of the prosecution, for even if the latter's evidence is weak, it could not be disbelieved after he has admitted the killing.[20] Here appellants failed to discharge said burden. They have not shown clearly and convincingly that they acted in self-defense when they stabbed their victims.

GR No. 127984

2001-12-14

JOSEFINA TANDO v. CA

QUISUMBING, J.

The issues raised in this petition, in our view, are factual. As a general rule, they are not reviewable by us in a petition for review. However, as there is a clear conflict between the factual findings of the trial court and the Court of Appeals, this case is an exception.[10] We are thus compelled to scrutinize closely the evidence to resolve the issues posed by petitioners.

GR No. 127695

2001-12-03

HEIRS OF LUIS BACUS v. CA AND SPS. FAUSTINO DURAY AND VICTORIANA DURAY

QUISUMBING, J.

We agree with private respondents that in a petition for review under Rule 45, only questions of law may be raised.[11] However, a close reading of petitioners' arguments reveal the following legal issues which may properly be entertained in the instant petition: a) When private respondents opted to buy the property covered by the lease contract with option to buy, were they already required to deliver the money or consign it in court before petitioner executes a deed of transfer? b) Did private respondents incur in delay when they did not deliver the purchase price or consign it in court on or before the expiration of the contract? On the first issue, petitioners contend that private respondents failed to comply with their obligation because there was neither actual delivery to them nor consignation in court or with the Municipal, City or Provincial Treasurer of the purchase price before the contract expired. Private respondents' bank certificate stating that arrangements were being made by the bank to release P700,000 as a loan to private respondents cannot be considered as legal tender that may substitute for delivery of payment to petitioners nor was it a consignation.

GR No. 127540

2001-10-17

EUGENIO DOMINGO v. CA

QUISUMBING, J.

While the issues raised in this petition might appear to be mainly factual, this petition is properly given due course because of the contradictory findings of the trial court and the Court of Appeals. Further, the latter court apparently overlooked certain relevant facts which justify a different conclusion.[12] Moreover, a compelling sense to make sure that justice is done, and done rightly in the light of the issues raised herein, constrains us from relying on technicalities alone to resolve this petition.

	GR No. 184355 2015-03-23	ARNULFO v. PEOPLE PERALTA, J.
As a rule, only questions of law may be raised in a petition for review under Rule 45 of the Rules of Court.[8] As such, we are not duty-bound to analyze and weigh all over again the evidence already considered in the proceedings below. The findings of facts by a trial court, when affirmed by the Court of Appeals, are binding on the Supreme Court.[9] This rule, however, is not without exceptions.[10] However, petitioner failed to show that his case falls under any of the exceptions.
	GR No. 185666 2015-02-04	NIPPON EXPRESS CORP. v. CIR PEREZ, J.
At the outset, in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[15] The Court is not a trier of facts and does not normally undertake the re-examination of the evidence presented by the contending parties during the trial of the case considering that the findings of facts of the (CTA) are conclusive and binding on the Court[16] and they carry even more weight when the (CTA En Banc) affirms the factual findings of the trial court.[17] However, this Court had recognized several exceptions to this rule,[18] including instances when the appellate court manifestly overlooked relevant facts not disputed by the parties, which, if properly considered, would probably justify a different conclusion.
	GR No. 185432 2014-06-04	MIRAMAR FISH COMPANY v. CIR PEREZ, J.
At the outset, this Court is not unaware that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[13] The Court is not a trier of facts and does not normally undertake the re-examination of the evidence presented by the contending parties during the trial of the case considering that the findings of facts of the [CTA] are conclusive and binding on the Court[14] and they carry even more weight when the [CTA En Banc] affirms the factual findings of the trial court.[15] However, this Court had recognized several exceptions to this rule,[16] including instances when the appellate court manifestly overlooked relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.
	GR No. 169778 2014-03-12	CIR v. SILICON PHILIPPINES PEREZ, J.
It is well settled that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised.[14] The Court is not a trier of facts and does not normally undertake the re-examination of the evidence presented by the contending parties during the trial of the case considering that the findings of facts of the CA are conclusive and binding on the Court[15] and they carry even more weight when the CA affirms the factual findings of the trial court.[16] However, the Court had recognized several exceptions to this rule, to wit: (1) when the findings are grounded entirely on speculation, surmises or conjectures; (2) when the inference made is manifestly mistaken, absurd or impossible; (3) when there is grave abuse of discretion; (4) when the judgment is based on a misapprehension of facts; (5) when the findings of facts are conflicting; (6) when in making its findings the CA went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (7) when the findings are contrary to the trial court; (8) when the findings are conclusions without citation of specific evidence on which they are based; (9) when the facts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondent; (10) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and (11) when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[17]
	GR No. 195002 2012-01-25	HECTOR TREÑAS v. PEOPLE SERENO, J.
(1) When the factual findings of the Court of Appeals and the trial court are contradictory; (2) When the conclusion is a finding grounded entirely on speculation, surmises or conjectures; (3) When the inference made by the Court of Appeals from its findings of fact is manifestly mistaken, absurd or impossible; (4) When there is grave abuse of discretion in the appreciation of facts; (5) When the appellate court, in making its findings, went beyond the issues of the case, and such findings are contrary to the admissions of both appellant and appellee; (6) When the judgment of the Court of Appeals is premised on misapprehension of facts; (7) When the Court of Appeals failed to notice certain relevant facts which, if properly considered, would justify a different conclusion; (8) When the findings of fact are themselves conflicting; (9) When the findings of fact are conclusions without citation of the specific evidence on which they are based; and (10) When the findings of fact of the Court of Appeals are premised on the absence of evidence but such findings are contradicted by the evidence on record.[14]
	GR No. 132604 2002-03-06	VENANCIO SAMBAR v. DOING BUSINESS UNDER NAME QUISUMBING, J.
We find that the first issue raised by petitioner is factual. The basic rule is that factual questions are beyond the province of this Court in a petition for review. Although there are exceptions to this rule, this case is not one of them.[5] Hence, we find no reason to disturb the findings of the Court of Appeals that Europress' use of the arcuate design was an infringement of the Levi's design.
	GR No. 134741 2001-12-19	SPS. BENNY CALVO AND JOVITA S. CALVO v. SPS. BERNARDITO AND ANGELINA VERGARA AND SPS. ALEXBERTO AND BELIBETH BASALO QUISUMBING, J.
In Reyes vs. Court of Appeals, G.R. No. 110207, 258 SCRA 651, 658 (1996), we distinguished between the two types of questions: there is a question of law when the doubt or difference arises as to what the law is pertaining to a certain state of facts, and there is a question of fact when the doubt arises as to the truth or falsity of alleged facts. Being a question of fact, it is beyond the office of this court in a petition for review under Rule 45 of the Revised Rules of Court, where only questions of law may be raised.[13] Although there are exceptions,[14] petitioners did not show that this is one of them. Additionally, petitioners, in raising the above issue, is in effect questioning the factual findings of the DARAB, contrary to the doctrine that findings of fact by administrative agencies are generally accorded great respect, if not finality by the courts because of the special knowledge and expertise over matters falling under their jurisdiction.[15] It must be stressed at this point that the DARAB has the jurisdiction on all agrarian disputes involving the implementation of agrarian laws, including PD 27.[16]
	GR No. 124809 2001-12-19	PEOPLE v. ROBERTO SAUL QUISUMBING, J.
Well-entrenched is the rule that one who invokes self-defense admits authorship of the killing, thus the burden shifts to that person to establish the justifying circumstance with clear and convincing evidence.[19] One who pleads it must rely on the strength of his own evidence and not on the weakness of that of the prosecution, for even if the latter's evidence is weak, it could not be disbelieved after he has admitted the killing.[20] Here appellants failed to discharge said burden. They have not shown clearly and convincingly that they acted in self-defense when they stabbed their victims.
	GR No. 127984 2001-12-14	JOSEFINA TANDO v. CA QUISUMBING, J.
The issues raised in this petition, in our view, are factual. As a general rule, they are not reviewable by us in a petition for review. However, as there is a clear conflict between the factual findings of the trial court and the Court of Appeals, this case is an exception.[10] We are thus compelled to scrutinize closely the evidence to resolve the issues posed by petitioners.
	GR No. 127695 2001-12-03	HEIRS OF LUIS BACUS v. CA AND SPS. FAUSTINO DURAY AND VICTORIANA DURAY QUISUMBING, J.
We agree with private respondents that in a petition for review under Rule 45, only questions of law may be raised.[11] However, a close reading of petitioners' arguments reveal the following legal issues which may properly be entertained in the instant petition: a) When private respondents opted to buy the property covered by the lease contract with option to buy, were they already required to deliver the money or consign it in court before petitioner executes a deed of transfer? b) Did private respondents incur in delay when they did not deliver the purchase price or consign it in court on or before the expiration of the contract? On the first issue, petitioners contend that private respondents failed to comply with their obligation because there was neither actual delivery to them nor consignation in court or with the Municipal, City or Provincial Treasurer of the purchase price before the contract expired. Private respondents' bank certificate stating that arrangements were being made by the bank to release P700,000 as a loan to private respondents cannot be considered as legal tender that may substitute for delivery of payment to petitioners nor was it a consignation.
	GR No. 127540 2001-10-17	EUGENIO DOMINGO v. CA QUISUMBING, J.
While the issues raised in this petition might appear to be mainly factual, this petition is properly given due course because of the contradictory findings of the trial court and the Court of Appeals. Further, the latter court apparently overlooked certain relevant facts which justify a different conclusion.[12] Moreover, a compelling sense to make sure that justice is done, and done rightly in the light of the issues raised herein, constrains us from relying on technicalities alone to resolve this petition.

NERIO SALCEDO Y MEDEL v. PEOPLE