This case has been cited 2 times or more.
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2014-04-07 |
LEONARDO-DE CASTRO, J. |
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| The existence of bad faith is a question of fact and is evidentiary.[33] The crucial question of whether or not a party has met his statutory duty to bargain in good faith typically turns on the facts of the individual case, and good faith or bad faith is an inference to be drawn from the facts.[34] Thus, the issue of whether or not there was bad faith on the part of the company when it was bargaining with the union is a question of fact. It requires that the reviewing court look into the evidence to find if indeed there is proof that is substantial enough to show such bad faith. | |||||
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2013-10-14 |
REYES, J. |
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| In this case, the RTC dismissed the petitioners' complaint with the bare statement that "the title of the [respondent's] predecessor Eufracio Lopez was issued on October 11, 1972 and the same has not as yet been judicially declared null and void by any competent court up to the present, as against [petitioners'] complaint which was filed with [the RTC] only on September 26, 2003, or more than thirty (30) years have lapsed before [petitioners] instituted [the] present action."[16] The RTC simply reckoned the commencement of the prescriptive period on the issuance of Lopez's title on October 11, 1972, as alleged by the respondent in its answer. In their complaint, however, the petitioners disputed the validity of the respondent's title, alleged bad faith on the part of Lopez and the respondent, and reiterated the existence of the final and executory decision of the CA in Civil Case No. 1447. The petitioners also alleged in their complaint and appellants' brief that they are holders of TCT No. 18833 issued on September 20, 1999 pursuant to the CA decision in Civil Case No. 1447.[17] Thus, the petitioners prayed, both in their complaint and in their appellant's brief, that the respondent's title be set aside and their own title upheld. While the existence of different titles over the same property is an established fact, the allegations in the petitioners' complaint and appellants' brief as to the antecedent facts that led to the issuance of the titles create an uncertainty regarding the applicability of prescription and call for a calibration of the evidence on hand. This constitutes a question of fact and not a run-of-the-mill question of law as the CA would like to present it; more so since the petitioners charge the respondent and its predecessors-in-interest with bad faith. "[T]he question of whether a person acted with good faith or bad faith in purchasing and registering real property is a question of fact, x x x."[18] It is evidentiary and has to be established by the claimant with clear and convincing evidence, and this necessitates an examination of the evidence of all the parties.[19] In Macababbad, Jr., the Court also ruled that prescription is a question of fact where there is a need to determine the veracity of factual matters such as the date when the period to bring the action commenced to run.[20] | |||||