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GR No. 190384

2010-07-05

HEIRS OF SPS. CRISPULO FERRER AND ENGRACIA PUHAWAN v. CA

BRION, J.

the claimants, by themselves or through their predecessors-in-interest, have been in open, continuous, exclusive, and notorious possession and occupation of the land since June 12, 1945 or earlier.[28]

GR No. 185063

2009-07-23

SPS. LITA DE LEON AND FELIX RIO TARROSA v. ANITA B. DE LEON

VELASCO JR., J.

Thus, the question of whether petitioners were able to adduce proof to overthrow the presumption is a factual issue best addressed by the trial court. As a matter of long and sound practice, factual determinations of the trial courts,[18] especially when confirmed by the appellate court, are accorded great weight by the Court and, as rule, will not be disturbed on appeal, except for the most compelling reasons.[19] Petitioners have not, as they really cannot, rebut the presumptive conjugal nature of the lot in question. In this regard, the Court notes and quotes with approval the following excerpts from the trial court's disposition: The defendants, however, did not adduce any proof that the property in question was acquired solely by the efforts of [Bonifacio]. The established jurisprudence on the matter leads this Court to the conclusion that the property involved in this dispute is indeed the conjugal property of the deceased [Bonifacio] De Leon.

GR No. 168437

2009-01-08

LAURINIO GOMA v. CA

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]

GR NO. 154975

2007-01-29

GENERAL CREDIT CORPORATION v. ALSONS DEVELOPMENT

GARCIA, J.

In net effect, the definitive conclusion of the appellate court affirmatory of that of the trial court was that the bearer promissory note (Exh. "K") was a genuine and authentic instrument payable to the holder thereof. This factual determination, as a matter of long and sound appellate practice, deserves great weight and shall not be disturbed on appeal, save for the most compelling reasons,[17] such as when that determination is clearly without evidentiary support or when grave abuse of discretion has been committed.[18] This is as it should be since the Court, in petitions for review of CA decisions under Rule 45 of the Rules of Court, usually limits its inquiry only to questions of law. Stated otherwise, it is not the function of the Court to analyze and weigh all over again the evidence or premises supportive of the factual holdings of lower courts.[19]

GR NO. 152007

2007-01-22

PROCOPIO TAPUROC v. MENDE

GARCIA, J.

SECTION 1. Filing of petition with Supreme Court. A party desiring to appeal by certiorari from a judgment or final order or resolution of the Court of Appeals, the Sandiganbayan, the Regional Trial Court or other courts whenever authorized by law, may file with the Supreme Court a verified petition for review on certiorari. The petition shall raise only questions of law which must be distinctly set forth. (Emphasis supplied) Evident it is from the above that the function of the Court in petitions for review on certiorari is limited to reviewing errors of law that may have been committed by the lower courts. And, as a matter of sound practice and procedure, the Court defers and accords finality to the factual findings of trial courts, more so when, as here, such findings are undisturbed by the appellate court. This factual determination, as a matter of long and sound appellate practice, deserves great weight and shall not be disturbed on appeal, save only for the most compelling reasons,[10] such as when that determination is clearly without evidentiary support or when grave abuse of discretion has been committed.[11] This is as it should be since the Court, in petitions for review of CA decisions under Rule 45 of the Rules of Court, usually limits its inquiry only to questions of law. Stated otherwise, it is not the function of the Court to analyze and weigh all over again the evidence or premises supportive of the factual holdings of lower courts.[12] The Court refrains from further scrutiny of factual findings of trial courts, more so when those findings are affirmed by the CA, as here. To do otherwise would defeat the very essence of Rule 45 and would convert the Court into a trier of facts, which it is not meant to be.[13]

GR NO. 150644

2006-08-28

EDWARD V. LACSON v. MAOWEE DABAN LACSON

GARCIA, J.

The Court finds no adequate reason to disturb the factual determination of the CA confirmatory of that of the trial court respecting the demand Lea made on the petitioner to secure support for the respondents. As a matter of long and sound appellate practice, factual findings of the CA are accorded respect, if not finality, save for the most compelling and cogent reasons.[10] Not one of the well-recognized exceptions to this rule on conclusiveness of factual findings appear to obtain in this case. Accordingly, the Court cannot grant the petitioner's plea for a review of the CA's findings bearing on the actuality that, as basis for an award of support in arrears, an extrajudicial demand for support had been made on the petitioner as evidenced by the December 10, 1975 note adverted to. Lest it be overlooked, the jurisdiction of the Court in a petition for review, as here, is generally limited to correction of errors of law. Complementing that postulate is the rule that the Court is not bound to analyze and weigh all over again the evidence already considered in the proceedings below,[11] except when, as earlier indicated, compelling reasons demand a review of the factual conclusions drawn from such evidence.

GR NO. 146527

2005-01-31

REPUBLIC v. MANNA PROPERTIES

CARPIO, J.

The issue of whether Manna Properties has presented sufficient proof of the required possession, under a bona fide claim of ownership, raises a question of fact.[8] It invites an evaluation of the evidentiary record. Petitioner invites us to re-evaluate the evidence and substitute our judgment for that of the trial and appellate courts. Generally, Rule 45 does not allow this. Matters of proof and evidence are beyond the power of this Court to review under a Rule 45 petition, except in the presence of some meritorious circumstances.[9] We find one such circumstance in this case. The evidence on record does not support the conclusions of both the trial court and the Court of Appeals.

GR NO. 161029

2005-01-19

SPRINGSUN MANAGEMENT SYSTEMS CORPORATION v. OSCAR CAMERINO

SANDOVAL-GUTIERREZ, J.

On the second assigned error, petitioner faults the Court of Appeals in affirming the trial court's finding that respondents are tenants on the questioned lots. Whether or not respondents are tenants is a question of fact which calls for a review of the parties' evidence. This, certainly, is impermissible as this Court is not a trier of facts. Our jurisdiction in cases brought before us from the Court of Appeals is limited to reviewing and correcting errors of law and not errors of facts allegedly committed by the latter.[38]

GR No. 160421

2004-10-04

SPS. PHILIP RECTO AND ESTER C. RECTO v. REPUBLIC

YNARES-SATIAGO, J.

In the instant case, Rosita and Maria the predecessors-in-interest of petitioners, categorically testified that they, and prior to them their father, had been cultivating and possessing Lot 806 in the concept of owners. Maria, having been born on October 22, 1917, and Rosita on October 29, 1922, were 13 years of age when they became aware of their family's possession of Lot 806 in 1930 and 1935, respectively. At 13, they were undoubtedly capable and competent to perceive their father's possession of Lot 806 in the concept of owner. Moreover, the trial court found their testimonies to be worthy of belief and credence. Considering that the judge below is in a better position to pass judgment on the issue, having personally heard the witnesses testify and observed their deportment and manner of testifying, her findings deserve the highest respect.[25]

GR No. 155012

2004-04-14

REPUBLIC v. CARMENCITA M. ALCONABA

DAVIDE JR., CJ.

The records also reveal that the subject property was declared for taxation purposes by the respondents only for the year 1994. They paid the taxes thereon only for the years 1990, 1991, 1992, 1994, 1996, and 1997. Being of recent dates, we cannot trust the assertion of the respondents that they immediately took possession of the property in the concept of an owner after the death of their parents. While belated declaration of a property for taxation purposes does not necessarily negate the fact of possession,[28] tax declarations or realty tax payments of property are, nevertheless, good indicia of possession in the concept of an owner, for no one in his right mind would be paying taxes for a property that is not in his actual or, at least, constructive possession.[29]

GR No. 142381

2003-10-15

PHILIPPINE BLOOMING MILLS v. CA

CARPIO, J.

Ching's attempts to have this Court review the factual issues of the case are improper. It is not a function of the Supreme Court to assess and evaluate again the evidence, testimonial and evidentiary, adduced by the parties particularly where the findings of both the trial court and the appellate court coincide on the matter. [53]

GR No. 150413

2003-07-01

REPUBLIC v. ALEXANDRA LAO

YNARES-SANTIAGO, J.

Under the public land act, judicial confirmation of imperfect title required possession en concepto de dueño since time immemorial, or since July 26, 1894. Under C.A. No. 141, this requirement was retained. However, on June 22, 1957, Republic Act No. 1942 was enacted amending C.A. No. 141. This later enactment required adverse possession for a period of only thirty (30) years. On January 25, 1977, the President enacted P.D. No. 1073, further amending C.A. No. 141, extending the period for filing applications for judicial confirmation of imperfect or incomplete titles to December 31, 1987. Under this decree, "the provisions of Section 48 (b) and Section 48 (c), Chapter VIII, of the Public Land Act are hereby amended in the sense that these provisions shall apply only to alienable and disposable land of the public domain which have been in open, continuous, exclusive and notorious possession and occupation by the applicant himself or thru his predecessors-in-interest under a bona fide claim of acquisition of ownership, since June 12, 1945. The aforequoted ruling was reiterated in Republic v. Court of Appeals,[12] thus:This Court has held in Republic vs. Doldol [295 SCRA 359, (1998)] that, originally, "Section 48(b) of C.A. No. 141 provided for possession and occupation of lands of the public domain since July 26, 1894. This was superseded by R.A. No. 1942 which provided for a simple thirty-year prescriptive period of occupation by an applicant for judicial confirmation of imperfect title. The same, however, has already been amended by Presidential Decree No. 1073, approved on January 25, 1977." As amended Section 48 (b) now reads:

	GR No. 190384 2010-07-05	HEIRS OF SPS. CRISPULO FERRER AND ENGRACIA PUHAWAN v. CA BRION, J.
the claimants, by themselves or through their predecessors-in-interest, have been in open, continuous, exclusive, and notorious possession and occupation of the land since June 12, 1945 or earlier.[28]
	GR No. 185063 2009-07-23	SPS. LITA DE LEON AND FELIX RIO TARROSA v. ANITA B. DE LEON VELASCO JR., J.
Thus, the question of whether petitioners were able to adduce proof to overthrow the presumption is a factual issue best addressed by the trial court. As a matter of long and sound practice, factual determinations of the trial courts,[18] especially when confirmed by the appellate court, are accorded great weight by the Court and, as rule, will not be disturbed on appeal, except for the most compelling reasons.[19] Petitioners have not, as they really cannot, rebut the presumptive conjugal nature of the lot in question. In this regard, the Court notes and quotes with approval the following excerpts from the trial court's disposition: The defendants, however, did not adduce any proof that the property in question was acquired solely by the efforts of [Bonifacio]. The established jurisprudence on the matter leads this Court to the conclusion that the property involved in this dispute is indeed the conjugal property of the deceased [Bonifacio] De Leon.
	GR No. 168437 2009-01-08	LAURINIO GOMA v. CA 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]
	GR NO. 154975 2007-01-29	GENERAL CREDIT CORPORATION v. ALSONS DEVELOPMENT GARCIA, J.
In net effect, the definitive conclusion of the appellate court affirmatory of that of the trial court was that the bearer promissory note (Exh. "K") was a genuine and authentic instrument payable to the holder thereof. This factual determination, as a matter of long and sound appellate practice, deserves great weight and shall not be disturbed on appeal, save for the most compelling reasons,[17] such as when that determination is clearly without evidentiary support or when grave abuse of discretion has been committed.[18] This is as it should be since the Court, in petitions for review of CA decisions under Rule 45 of the Rules of Court, usually limits its inquiry only to questions of law. Stated otherwise, it is not the function of the Court to analyze and weigh all over again the evidence or premises supportive of the factual holdings of lower courts.[19]
	GR NO. 152007 2007-01-22	PROCOPIO TAPUROC v. MENDE GARCIA, J.
SECTION 1. Filing of petition with Supreme Court. A party desiring to appeal by certiorari from a judgment or final order or resolution of the Court of Appeals, the Sandiganbayan, the Regional Trial Court or other courts whenever authorized by law, may file with the Supreme Court a verified petition for review on certiorari. The petition shall raise only questions of law which must be distinctly set forth. (Emphasis supplied) Evident it is from the above that the function of the Court in petitions for review on certiorari is limited to reviewing errors of law that may have been committed by the lower courts. And, as a matter of sound practice and procedure, the Court defers and accords finality to the factual findings of trial courts, more so when, as here, such findings are undisturbed by the appellate court. This factual determination, as a matter of long and sound appellate practice, deserves great weight and shall not be disturbed on appeal, save only for the most compelling reasons,[10] such as when that determination is clearly without evidentiary support or when grave abuse of discretion has been committed.[11] This is as it should be since the Court, in petitions for review of CA decisions under Rule 45 of the Rules of Court, usually limits its inquiry only to questions of law. Stated otherwise, it is not the function of the Court to analyze and weigh all over again the evidence or premises supportive of the factual holdings of lower courts.[12] The Court refrains from further scrutiny of factual findings of trial courts, more so when those findings are affirmed by the CA, as here. To do otherwise would defeat the very essence of Rule 45 and would convert the Court into a trier of facts, which it is not meant to be.[13]
	GR NO. 150644 2006-08-28	EDWARD V. LACSON v. MAOWEE DABAN LACSON GARCIA, J.
The Court finds no adequate reason to disturb the factual determination of the CA confirmatory of that of the trial court respecting the demand Lea made on the petitioner to secure support for the respondents. As a matter of long and sound appellate practice, factual findings of the CA are accorded respect, if not finality, save for the most compelling and cogent reasons.[10] Not one of the well-recognized exceptions to this rule on conclusiveness of factual findings appear to obtain in this case. Accordingly, the Court cannot grant the petitioner's plea for a review of the CA's findings bearing on the actuality that, as basis for an award of support in arrears, an extrajudicial demand for support had been made on the petitioner as evidenced by the December 10, 1975 note adverted to. Lest it be overlooked, the jurisdiction of the Court in a petition for review, as here, is generally limited to correction of errors of law. Complementing that postulate is the rule that the Court is not bound to analyze and weigh all over again the evidence already considered in the proceedings below,[11] except when, as earlier indicated, compelling reasons demand a review of the factual conclusions drawn from such evidence.
	GR NO. 146527 2005-01-31	REPUBLIC v. MANNA PROPERTIES CARPIO, J.
The issue of whether Manna Properties has presented sufficient proof of the required possession, under a bona fide claim of ownership, raises a question of fact.[8] It invites an evaluation of the evidentiary record. Petitioner invites us to re-evaluate the evidence and substitute our judgment for that of the trial and appellate courts. Generally, Rule 45 does not allow this. Matters of proof and evidence are beyond the power of this Court to review under a Rule 45 petition, except in the presence of some meritorious circumstances.[9] We find one such circumstance in this case. The evidence on record does not support the conclusions of both the trial court and the Court of Appeals.
	GR NO. 161029 2005-01-19	SPRINGSUN MANAGEMENT SYSTEMS CORPORATION v. OSCAR CAMERINO SANDOVAL-GUTIERREZ, J.
On the second assigned error, petitioner faults the Court of Appeals in affirming the trial court's finding that respondents are tenants on the questioned lots. Whether or not respondents are tenants is a question of fact which calls for a review of the parties' evidence. This, certainly, is impermissible as this Court is not a trier of facts. Our jurisdiction in cases brought before us from the Court of Appeals is limited to reviewing and correcting errors of law and not errors of facts allegedly committed by the latter.[38]
	GR No. 160421 2004-10-04	SPS. PHILIP RECTO AND ESTER C. RECTO v. REPUBLIC YNARES-SATIAGO, J.
In the instant case, Rosita and Maria the predecessors-in-interest of petitioners, categorically testified that they, and prior to them their father, had been cultivating and possessing Lot 806 in the concept of owners. Maria, having been born on October 22, 1917, and Rosita on October 29, 1922, were 13 years of age when they became aware of their family's possession of Lot 806 in 1930 and 1935, respectively. At 13, they were undoubtedly capable and competent to perceive their father's possession of Lot 806 in the concept of owner. Moreover, the trial court found their testimonies to be worthy of belief and credence. Considering that the judge below is in a better position to pass judgment on the issue, having personally heard the witnesses testify and observed their deportment and manner of testifying, her findings deserve the highest respect.[25]
	GR No. 155012 2004-04-14	REPUBLIC v. CARMENCITA M. ALCONABA DAVIDE JR., CJ.
The records also reveal that the subject property was declared for taxation purposes by the respondents only for the year 1994. They paid the taxes thereon only for the years 1990, 1991, 1992, 1994, 1996, and 1997. Being of recent dates, we cannot trust the assertion of the respondents that they immediately took possession of the property in the concept of an owner after the death of their parents. While belated declaration of a property for taxation purposes does not necessarily negate the fact of possession,[28] tax declarations or realty tax payments of property are, nevertheless, good indicia of possession in the concept of an owner, for no one in his right mind would be paying taxes for a property that is not in his actual or, at least, constructive possession.[29]
	GR No. 142381 2003-10-15	PHILIPPINE BLOOMING MILLS v. CA CARPIO, J.
Ching's attempts to have this Court review the factual issues of the case are improper. It is not a function of the Supreme Court to assess and evaluate again the evidence, testimonial and evidentiary, adduced by the parties particularly where the findings of both the trial court and the appellate court coincide on the matter. [53]
	GR No. 150413 2003-07-01	REPUBLIC v. ALEXANDRA LAO YNARES-SANTIAGO, J.
Under the public land act, judicial confirmation of imperfect title required possession en concepto de dueño since time immemorial, or since July 26, 1894. Under C.A. No. 141, this requirement was retained. However, on June 22, 1957, Republic Act No. 1942 was enacted amending C.A. No. 141. This later enactment required adverse possession for a period of only thirty (30) years. On January 25, 1977, the President enacted P.D. No. 1073, further amending C.A. No. 141, extending the period for filing applications for judicial confirmation of imperfect or incomplete titles to December 31, 1987. Under this decree, "the provisions of Section 48 (b) and Section 48 (c), Chapter VIII, of the Public Land Act are hereby amended in the sense that these provisions shall apply only to alienable and disposable land of the public domain which have been in open, continuous, exclusive and notorious possession and occupation by the applicant himself or thru his predecessors-in-interest under a bona fide claim of acquisition of ownership, since June 12, 1945. The aforequoted ruling was reiterated in Republic v. Court of Appeals,[12] thus:This Court has held in Republic vs. Doldol [295 SCRA 359, (1998)] that, originally, "Section 48(b) of C.A. No. 141 provided for possession and occupation of lands of the public domain since July 26, 1894. This was superseded by R.A. No. 1942 which provided for a simple thirty-year prescriptive period of occupation by an applicant for judicial confirmation of imperfect title. The same, however, has already been amended by Presidential Decree No. 1073, approved on January 25, 1977." As amended Section 48 (b) now reads: