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AQUILA LARENA JOINED BY HER HUSBAND v. FRUCTUOSA MAPILI

This case has been cited 18 times or more.

2012-12-05
PERALTA, J.
The receipt dated October 23, 1972 cannot prove ownership over the subject property as respondent Beatriz Miranda's signature on the receipt, as vendor, has been found to be forged by the NBI handwriting expert, the trial court and the Court of Appeals.  It is a settled rule that the factual findings of the Court of Appeals affirming those of the trial court are final and conclusive and may not be reviewed on appeal, except under any of the following circumstances: (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference is manifestly mistaken, absurd or impossible; (3) there is grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of fact are conflicting; (6) there is no citation of specific evidence on which the factual findings are based; (7) the finding of absence of facts is contradicted by the presence of evidence on record; (8) the findings of the CA are contrary to those of the trial court; (9) the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; (10) the findings of the CA are beyond the issues of the case; and (11) such findings are contrary to the admissions of both parties.[27]
2012-12-05
PEREZ, J.
The tenor of the first ground raised by LISI in support of its petition impels us to call its counsel's attention to the basic rule that grave abuse of discretion is beyond the scope of appeals by certiorari like the one at bench.[24] Considering that only questions of law may be raised in a Rule 45 petition for review on certiorari, the well-entrenched doctrine is also to the effect that questions of fact are not proper subjects in this mode of appeal.[25] When supported by substantial evidence, the findings of fact of the Court of Appeals are conclusive and binding on the parties, and are not reviewed by this Court except when the findings are contrary with those of the lower court or quasi-judicial bodies.[26] Since the CA's factual findings can be questioned if they are, as here, contrary to those of the lower court and/or administrative agency,[27] we find that respondents cannot, in turn, argue that this Court has no jurisdiction to entertain the questions of fact pertinent to the grounds raised in support of LISI's petition.
2012-03-14
CARPIO, J.
When supported by substantial evidence, the factual findings of the CA affirming those of the trial court[15] are final and conclusive on this Court and may not be reviewed on appeal,[16] unless petitioner can show compelling or exceptional reasons[17] for this Court to disregard, overturn or modify such findings.
2010-11-15
NACHURA, J.
The Court has consistently ruled that findings of fact of trial courts are entitled to great weight and should not be disturbed, except for strong and valid reasons, because the trial court is in a better position to examine the demeanor of witnesses while testifying. It is not a function of this Court to analyze and weigh evidence all over again.[23] The factual findings of the CA affirming those of the trial court are final and conclusive;[24] hence, they are binding on this Court.
2009-12-14
DEL CASTILLO, J.
Petitioners' acts of a possessory character - acts that might have been merely tolerated by the owner - did not constitute possession. No matter how long tolerated possession is continued, it does not start the running of the prescriptive period.[30] Mere material possession of land is not adverse possession as against the owner and is insufficient to vest title, unless such possession is accompanied by the intent to possess as an owner. There should be a hostile use of such a nature and exercised under such circumstance as to manifest and give notice that the possession is under a claim of right.[31]
2007-09-03
CHICO-NAZARIO, J.
Of course, this Court may be minded to review the factual findings of the Court of Appeals, but only in the presence of any of the following circumstances: (1) the conclusion is grounded on speculations, surmises or conjectures;[46] (2) the interference is manifestly mistaken, absurd or impossible;[47] (3) there is grave abuse of discretion;[48] (4) the judgment is based on a misapprehension of facts;[49] (5) the findings of fact are conflicting;[50] (6) there is no citation of specific evidence on which the factual findings are based;[51] (7) the findings of fact are contradicted by the presence of evidence on record;[52] (8) the findings of the Court of Appeals are contrary to those of the trial court;[53] (9) the Court of Appeals manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion;[54] (10) the findings of the Court of Appeals are beyond the issues of the case;[55] and (11) such findings are contrary to the admissions of both parties.[56]
2006-06-20
TINGA, J.
Although this rule admits of several exceptions,[22] none of the exceptions is available in the instant case which gives us reason to deviate from the rule. The courts a quo had sufficient factual basis in holding that the questioned signatures are spurious.
2005-12-16
Laches is the failure or neglect, for an unreasonable and unexplained length of time, to do that which could or should have been done earlier through the exercise of due diligence.[8] Otherwise stated, laches is the negligence or omission to assert a right within a reasonable time warranting a presumption that the party entitled to assert it has either abandoned or declined to assert it.[9] Its elements are: (1) conduct on the part of the defendant, or of one under whom he claims, giving rise to the situation for which the complaint seeks a remedy; (2) delay in asserting the complainant's rights, the complainant having had knowledge or notice of the defendant's conduct as having been afforded an opportunity to institute a suit; (3) lack of knowledge or notice on the part of the defendant that the complainant would assert the right in which he bases his suit; and (4) injury or prejudice to the defendant in the event, relief is accorded to the complainant, or the suit is not held barred.[10]
2005-09-30
CORONA, J.
The issues raised by petitioners are purely factual.   The Court, not being a trier of facts, does not normally re-examine the evidence submitted by the contending parties during the trial of a case.  Findings of fact of the Court of Appeals, affirming those of the trial court, are final and conclusive.[17]  The jurisdiction of the Court in a petition for review on certiorari is limited to reviewing only errors of law, not of fact, unless it is shown, inter alia, that: (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference  is  manifestly  mistaken,  absurd  and  impossible; (3) there is grave abuse of discretion; (4) the judgment is based on misapprehension of facts; (5) the findings of fact are conflicting and (6) the Court of Appeals went beyond the issues of the case and its findings are contrary to the admissions of both parties.[18]
2005-08-31
CALLEJO, SR., J.
Prefatorily, the rule is that, only questions of facts may be raised in a petition for review on certiorari under Rule 45 of the Rules of Court, as amended. However, the rule allows exceptions, such as in this case where (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference is manifestly mistaken, absurd or impossible; (3) there is grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of fact are conflicting; (6) there is no citation of specific evidence on which the factual findings are based; (7) the finding of absence of facts is contradicted by the presence of evidence on record; (8) the findings of the CA are contrary to those of the trial court; (9) the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; (10) the findings of the CA are beyond the issues of the case; and (11) such findings are contrary to the admissions of both parties.[45]
2005-08-09
CALLEJO, SR., J.
At the outset, it must be stressed that only questions of law may be raised by the parties and passed upon by the Supreme Court in petitions for review on certiorari.[38] Findings of fact of the CA, affirming those of the trial court, are final and conclusive and may not be reviewed on appeal.[39]
2005-07-28
PANGANIBAN, J.
Petitioner has not shown any exceptional circumstance that sanctions the disregard of these findings of fact, which are thus deemed final and conclusive upon this Court and may not be reviewed on appeal.[8]
2004-12-10
PANGANIBAN, J.
To begin with, this Court is not a trier of facts. [21] It is not its function to examine and determine the weight of the evidence. Well-entrenched is the doctrine that only errors of law,[22] and not of facts, are reviewable by this Court in a petition for review on certiorari under Rule 45 of the Revised Rules of Court. Philippine Airlines, Inc. v. Court of Appeals[23] has held that factual findings of the Court of Appeals are binding and conclusive upon the Supreme Court. These findings may be reviewed[24] only under exceptional circumstances such as, among others, when the inference is manifestly mistaken;[25] the judgment is based on a misapprehension of facts;[26] findings of the trial court contradict those of the CA;[27] or the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion.[28]
2004-09-20
PANGANIBAN, J.
At the outset, it must be stressed that only questions of law[13] may be raised in a petition for review on certiorari under Rule 45 of the Rules of Court.  Questions of fact are not proper subjects in this mode of appeal,[14] for "[t]he Supreme Court is not a trier of facts."[15] Factual findings of the CA may be reviewed on appeal[16] only under exceptional circumstances such as, among others, when the inference is manifestly mistaken,[17] the judgment is based on a    misapprehension of facts,[18] or the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion.[19]
2004-07-30
PANGANIBAN, J.
At the outset, it must be stressed that only questions of law[12] may be raised in a petition for review on certiorari under Rule 45 of the Rules of Court. As a rule, questions of fact cannot be the subject of this mode of appeal,[13] for "[t]he Supreme Court is not a trier of facts."[14] As exceptions to this rule, however, factual findings of the CA may be reviewed on appeal[15] when, inter alia, the factual inferences are manifestly mistaken;[16] the judgment is based on a misapprehension of facts;[17] or the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different legal conclusion.[18] In the present case, these exceptions exist in various instances, thus prompting us to take cognizance of factual issues and to decide upon them in the interest of justice and in the exercise of our sound discretion.[19]
2004-02-17
AUSTRIA-MARTINEZ, J.
The first and second issues require the determination of factual matters which is beyond the province of the Supreme Court.[11] It is settled that only questions of law are entertained in petitions for review on certiorari under Rule 45 of the Rules of Court.[12] The trial court's findings of fact, especially when affirmed by the Court of Appeals, are generally binding and conclusive upon the Supreme Court.[13] It is true that there are recognized exceptions to this rule, among which are: (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference is manifestly mistaken, absurd or impossible; (3) there is grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of fact are conflicting; (6) there is no citation of specific evidence on which the factual findings are based; (7) the finding of absence of facts is contradicted by the presence of evidence on record; (8) the findings of the CA are contrary to the findings of  the  trial  court;  (9)  the  CA  manifestly  overlooked  certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; (10) the findings of the CA are beyond the issues of the case; and, (11) such findings are contrary to the admissions of both parties;[14] but petitioners failed to show that any of the exceptions is present in the instant case to warrant a review of the findings of fact of the lower courts.
2003-12-08
AUSTRIA-MARTINEZ, J.
FINALLY, the Court of Appeals erred in affirming the amount of damages adjudicated by the Court below, which is at best speculative and not supported by damages.[5] The general rule is that only questions of law are entertained in petitions for review by certiorari under Rule 45 of the Rules of Court.  The trial court's findings of fact, which the Court of Appeals affirmed, are generally binding and conclusive upon this court.[6] There are recognized exceptions to this rule, among which are: (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference is manifestly mistaken, absurd or impossible; (3) there is grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of facts are conflicting; (6) there is no citation of specific evidence on which the factual findings are based; (7) the finding of absence of facts is contradicted by the presence of evidence on record; (8) the findings of the CA are contrary to the findings of the trial court; (9) the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; (10) the findings of the CA are beyond the issues of the case; and (11) such findings are contrary to the admissions of both parties.[7] Petitioner failed to demonstrate that its petition falls under any one of the above exceptions, except as to damages which will be discussed forthwith.
2003-12-08
SANDOVAL-GUTIERREZ, J.
While it is firmly entrenched in our jurisdiction that only questions of law may be entertained by this Court in a petition for review on certiorari, however, such rule is not ironclad and admits certain exceptions, such as when: (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference is manifestly mistaken, absurd or impossible; (3) there is grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of fact are conflicting; (6) there is no citation of specific evidence on which the factual findings are based; (7) the finding of absence of facts is contradicted by the presence of evidence on record; (8) the findings of the Court of Appeals are contrary to those of the trial court; (9) the Court of Appeals manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; (10) the findings of the Court of Appeals are beyond the issues of the case; and (11) such findings are contrary to the admissions of both parties.[5] Here, we find that the trial court and the Court of Appeals misapprehended and overlooked relevant and established facts.