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CESAR SAMPAYAN v. CA

This case has been cited 15 times or more.

2013-01-14
BERSAMIN, J.
It is a settled rule, indeed, that in the exercise of our power of review, 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. The Court relies on the findings of fact of the Court of Appeals or of the trial court, and accepts such findings as conclusive and binding unless any of the following exceptions obtains, namely: (a) when the findings are grounded entirely on speculation, surmises or conjectures; (b) when the inference made is manifestly mistaken, absurd or impossible; (c) when there is grave abuse of discretion; (d) when the judgment is based on a misapprehension of facts; (e) when the findings of facts are conflicting; (f) when in making its findings the Court of Appeals or the trial court went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (g) when the findings are contrary to the trial court; (h) when the findings are conclusions without citation of specific evidence on which they are based; (i) 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; (j) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and (k) when the Court of Appeals or the trial court manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[15] However, none of the aforementioned exceptions applies herein.
2011-11-23
BERSAMIN, J.
It is true that the Court has recognized several exceptions, in which it has undertaken the review and re-appreciation of the evidence. Among the exceptions have been: (a) when the findings of the CA are grounded entirely on speculation, surmises or conjectures; (b) when the inference made by the CA is manifestly mistaken, absurd or impossible; (c) when there is grave abuse of discretion on the part of the CA; (d) when the judgment of the CA is based on a misapprehension of facts; (e) when the findings of facts of the CA are conflicting; (f) when the CA, in making its findings, went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (g) when the findings of the CA are contrary to those of the trial court; (h) when the findings of the CA are conclusions without citation of specific evidence on which they are based; (i) 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; (j) when the findings of fact of the CA are premised on the supposed absence of evidence and contradicted by the evidence on record; and (k) when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[33]
2011-09-21
BERSAMIN, J.
Although the Court has recognized several exceptions to the limitation of an appeal by certiorari to only questions of law, including: (a) when the findings are grounded entirely on speculation, surmises or conjectures; (b) when the inference made is manifestly mistaken, absurd or impossible; (c) when there is grave abuse of discretion; (d) when the judgment is based on a misapprehension of facts; (e) when the findings of facts are conflicting; (f) when in making its findings the Court of Appeals went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (g) when the findings are contrary to those of the trial court; (h) when the findings are conclusions without citation of specific evidence on which they are based; (i) 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; (j) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and (k) when the Court of Appeals manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion,[12] this appeal does not come under the exceptions.
2011-09-21
BERSAMIN, J.
Nonetheless, the Court has recognized several exceptions to the rule, including: (a) when the findings are grounded entirely on speculation, surmises or conjectures; (b) when the inference made is manifestly mistaken, absurd or impossible; (c) when there is grave abuse of discretion; (d) when the judgment is based on a misapprehension of facts; (e) when the findings of facts are conflicting; (f) when in making its findings the Court of Appeals went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (g) when the findings are contrary to those of the trial court; (h) when the findings are conclusions without citation of specific evidence on which they are based; (i) 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; (j) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and (k) when the Court of Appeals manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[14] The circumstances of this case indicate that none of such exceptions is attendant herein.
2011-03-16
BERSAMIN, J.
The restriction of the review to questions of law emanates from the Court's not being a trier of facts.  As such, the Court cannot determine factual issues in appeals taken from the lower courts.  As the consequence of the restriction, the Court accords high respect, if not conclusive effect, to the findings of fact by the RTC, when affirmed by the CA,[11] unless there exists an exceptional reason to disregard the findings of fact, like the following, namely:[12]
2011-02-23
BERSAMIN, J.
It is true that the Court has, at times, allowed exceptions from the restriction. Among the recognized exceptions are the following, to wit:[9]
2009-10-27
CHICO-NAZARIO, J.
After an exhaustive review of the evidence on record, the Court finds that respondent was not able to satisfactorily prove her prior physical possession, nor her being deprived thereof by petitioner through force, intimidation, threat, strategy, and stealth. It is noteworthy that absence alone of prior physical possession by the plaintiff in a forcible entry case already warrants the dismissal of the complaint.[32]
2009-01-08
VELASCO JR., J.
And this factual determination, as a matter of long and sound appellate practice, deserves great weight and shall not be disturbed on appeal, except only for the most convincing reasons,[14] such as when that determination is clearly without evidentiary support on record[15] or when the judgment is based on misapprehension of facts or overlooked certain relevant facts which, if properly considered, would justify a different conclusion.[16] This is as it should be since it is not the function of the Court under Rule 45 of the Rules of Court to evaluate and weigh all over again the evidence presented or the premises supportive of the factual holdings of lower courts.[17]
2008-07-04
VELASCO JR., J.
An action for forcible entry is summary in nature. It is designed to recover physical possession through prompt proceedings that are restrictive in nature, scope, and time limits. [4] In such action, the plaintiff must prove that he was in prior possession of the land or building and that he was deprived thereof by means of force, intimidation, threat, strategy, or stealth.[5]
2008-04-09
VELASCO JR., J.
(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 [of the CA] 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 Court of Appeals manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[12] (Emphasis supplied.)
2007-02-02
VELASCO, JR., J.
"[i]t is a settled rule that in the exercise of the Supreme Court's power of review, 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.  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 Court of Appeals 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 Court of Appeals manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion."[42] A perusal of the exceptions enumerated above reveals that the instant case does not fall under any of them. Thus, this Court cannot entertain the factual issues raised in the petition, which include the issue of authenticity of the Undertaking or Agreement, as well as the issue of non-payment of the amount mentioned, particularly, in the Undertaking.
2006-07-21
GARCIA, J.
To the mind of the Court, respondent's entitlement to rentals turns on the nature of the gasoline station being operated by Tan Pastor on the subject lot. To resolve this, we must necessarily venture into determining whether the gasoline station thereat was dealer-owned or company-owned. Undoubtedly, this exercise involves an examination of facts which is normally beyond the ambit of this Court. For, well-settled is the rule that this Court, not being a trier of facts, does not normally embark in the evaluation of evidence adduced during trial. The rule, however, admits of exceptions. So it is that in Sampayan v. Court of Appeals,[10] the Court held:"[i]t is a settled rule that in the exercise of the Supreme Court's power of review, 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. 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 Court of Appeals 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 Court of Appeals manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion."
2006-02-22
YNARES-SANTIAGO, J.
The above conclusions of the MCTC show that the improvements on the property were introduced by persons other than the respondents; that they were not found on the subject property, or were constructed and used by mere tolerance of petitioner's grandfather.  We accord considerable evidentiary weight to the conclusions of the MCTC since it was derived after an ocular inspection of the property in the presence of both parties and their respective counsels.   Moreover, the MCTC noted that the property in controversy is beyond the coverage of the tax declaration presented by the respondents.[25]  In Sampayan v. Court of Appeals,[26] we upheld the uncontested findings of the MCTC judge who himself conducted the ocular inspection of the contested premises.  Consequently, respondents' claim of prior possession of the contested property must fail.
2005-11-11
TINGA, J.
Undoubtedly, the exercise involves an examination of facts which is normally beyond the ambit of the Court's functions under Rule 45 of the Revised Rules of Court for it is a well-settled rule that this Court is not a trier of facts and the findings of facts of the Court of Appeals are conclusive and binding on the Court.  However, it is equally well-settled that this rule admits of exceptions,[33] such as when the findings of facts of the appellate court are contrary to those of the trial court's.  Obviously, the exception is present given the diverse rulings of the RTC and the Court of Appeals as to Paramount's liability.
2005-08-18
YNARES-SANTIAGO, J.
Whether petitioners are innocent mortgagee or purchasers in good faith and for value, is a factual matter, which cannot be raised in a petition for review on certiorari under Rule 45.[9] Settled is the rule that this Court is not a trier of facts and does not normally embark on a re-examination of the evidence adduced by the parties during trial.[10] In Heirs of the Late Spouses Aurelio and Esperanza Balite v. Lim,[11] we held that factual findings of the Court of Appeals are binding and conclusive upon us. These findings may be reviewed only under exceptional circumstances such as when the inference is manifestly mistaken; the judgment is based on a misapprehension of facts; findings of the trial court contradict those of the appellate court; or the latter manifestly overlooked relevant and undisputed facts that, if properly considered, would justify a different conclusion.