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EDENBERT MADRIGAL v. CA

This case has been cited 4 times or more.

2014-10-08
BERSAMIN, J.
It is true that the limitation of the review to errors of law admits of exceptions. Under Section 4, Rule 3 of the Internal Rules of the Supreme Court, the following situations are the exceptions in which the Court may review findings of fact by the lower courts, to wit: (a) the conclusion is a finding grounded entirely on speculation, surmise and conjecture; (b) the inference made is manifestly mistaken; (c) there is grave abuse of discretion; (d) the judgment is based on a misapprehension of facts; (e) the findings of fact are conflicting; (f) the collegial appellate courts went beyond the issues of the case, and their findings are contrary to the admissions of both appellant and appellee; (g) the findings of fact of the collegial appellate courts are contrary to those of the trial court; (h) said findings of fact are conclusions without citation of specific evidence on which they are based; (i) the facts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondents; (j) the findings of fact of the collegial appellate courts are premised on the supposed evidence, but are contradicted by the evidence on record; and (k) all other similar and exceptional cases warranting a review of the lower courts' findings of fact. A further exception is recognized when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[12] Yet, none of the exceptions applies herein.
2007-01-25
AZCUNA, J.
A prudent man knowing that payment is due him would have demanded payment by his debtor from the moment the same became due and demandable. More so if the sum involved runs in hundreds of thousand of pesos. By and large, every person, at the very moment he learns that he was deprived of a thing which rightfully belongs to him, would have created a big fuss. He would not have waited for a year within which to do so. It is most inconceivable that Templonuevo did not do this.[12] Generally, only questions of law may be raised in an appeal by certiorari under Rule 45 of the Rules of Court.[13] Factual findings of the CA are entitled to great weight and respect, especially when the CA affirms the factual findings of the trial court.[14] Such questions on whether certain items of evidence should be accorded probative value or weight, or rejected as feeble or spurious, or whether or not the proofs on one side or the other are clear and convincing and adequate to establish a proposition in issue, are questions of fact. The same holds true for questions on whether or not the body of proofs presented by a party, weighed and analyzed in relation to contrary evidence submitted by the adverse party may be said to be strong, clear and convincing, or whether or not inconsistencies in the body of proofs of a party are of such gravity as to justify refusing to give said proofs weight all these are issues of fact which are not reviewable by the Court.[15]
2005-12-15
YNARES-SANTIAGO, J.
Undoubtedly, the above issue is one of fact as it assails the factual finding of the Court of Appeals that respondent had not gone AWOL. Basic is the rule in this jurisdiction that only questions of law may be raised in a petition for review on certiorari under Rule 45 of the Rules of Court. The jurisdiction of the Supreme Court in cases brought to it from the Court of Appeals is limited to reviewing and revising the errors of law imputed to it, its findings of fact being conclusive,[16] save for the most cogent and compelling reason, like when the factual findings of the Court of Appeals and the trial court are contradictory.[17]
2005-06-23
AUSTRIA-MARTINEZ, J.
Second, well-settled is the rule that factual matters cannot be inquired into by this Court in an appeal by certiorari.[32] This Court, at this stage, is limited to reviewing errors of law that may have been committed by the lower courts. [33] We are, thus, constrained from conducting further scrutiny of the findings of fact made by the trial court.[34] Otherwise, we would convert this Court into a trier of facts.[35] There are recognized 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.[36] However, after a review of the instant case, we find that it does not fall under any of these exceptions.