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MAXIMINO FUENTES v. CA

This case has been cited 29 times or more.

2014-06-02
BRION, J.
Although there are exceptions to the rule that only questions of law may be raised in a petition for certiorari, the petitioner bank failed to show that this case falls under any of the established exceptions. Too, since the CA partially affirmed the findings of the trial court and absent any indication that these courts committed a serious error in its findings, this Court is bound by these courts' findings.[6]
2012-11-14
DEL CASTILLO, J.
Petitioner posits that Article 448 of the Civil Code does not apply and that respondent-spouses are not entitled to reimbursement of the value of the improvements made on the property because they were builders in bad faith.  At the outset, we emphasize that the issue of whether respondent-spouses are builders in good faith or bad faith is a factual question, which is beyond the scope of a petition filed under Rule 45 of the Rules of Court.[57]  In fact, petitioner is deemed to have waived all factual issues since it appealed the case directly to this Court,[58] instead of elevating the matter to the CA.  It has likewise not escaped our attention that after their failed preliminary conference, the parties agreed to submit the case for resolution based on the pleadings and exhibits presented.  No trial was conducted.  Thus, it is too late for petitioner to raise at this stage of the proceedings the factual issue of whether respondent-spouses are builders in bad faith.  Hence, in view of the special circumstances obtaining in this case, we are constrained to rely on the presumption of good faith on the part of the respondent-spouses which the petitioner failed to rebut.  Thus, respondent-spouses being presumed builders in good faith, we now rule on the applicability of Article 448 of the Civil Code.
2011-10-19
PERALTA, J.
The rule is that the jurisdiction of the Court over appealed cases from the Court of Appeals is limited to the review and revision of errors of law allegedly committed by the appellate court, as its findings of fact are deemed conclusive.[21]  Thus, this Court is not duty-bound to analyze and weigh all over again the evidence already considered in the proceedings below.[22] However, this rule admits exceptions,[23] such as when the findings of fact of the Court of Appeals are contrary to the findings and conclusions of the trial court[24] like in this case.
2011-06-15
VELASCO JR., J.
It is hornbook doctrine that the factual findings of the CA affirming those of the trial court are binding on this Court unless there is a clear showing that such findings are tainted with arbitrariness, capriciousness or palpable error. [65] In People v. Lusabio, Jr., this Court held: All in all, we find the evidence of the prosecution to be more credible than that adduced by accused-appellant. When it comes to credibility, the trial court's assessment deserves great weight, and is even conclusive and binding, if not tainted with arbitrariness or oversight of some fact or circumstance of weight and influence. The reason is obvious. Having the full opportunity to observe directly the witnesses' deportment and manner of testifying, the trial court is in a better position than the appellate court to evaluate testimonial evidence properly. [66] (Emphasis supplied; citations omitted)
2011-03-16
VELASCO JR., J.
Besides, the issue posed is one of credibility of witnesses, a matter that is peculiarly within the province of the trial court. [43] Absent a clear showing that the findings of the trial court are tainted with arbitrariness, capriciousness, or palpable error, We generally defer to its assessment.[44]
2011-01-26
VELASCO JR., J.
Time and again, this Court has held that factual findings of the appellate court affirming those of the trial court are binding on this Court, unless there is a clear showing that such findings are tainted with arbitrariness, capriciousness, or palpable error.[24]  In People v. Lusabio, Jr., [25] this Court held: All in all, we find the evidence of the prosecution to be more credible than that adduced by accused-appellant. When it comes to credibility, the trial court's assessment deserves great weight, and is even conclusive and binding, if not tainted with arbitrariness or oversight of some fact or circumstance of weight and influence. The reason is obvious. Having the full opportunity to observe directly the witnesses' deportment and manner of testifying, the trial court is in a better position than the appellate court to evaluate testimonial evidence properly.  (Emphasis supplied; citations omitted.)
2010-10-20
VELASCO JR., J.
In Fuentes v. Court of Appeals,[30] the Court established the rule of conclusiveness of factual findings of the CA as follows: Jurisprudence teaches us that "(a)s a rule, the jurisdiction of this Court in cases brought to it from the Court of Appeals x x x is limited to the review and revision of errors of law allegedly committed by the appellate court, as its findings of fact are deemed conclusive.  As such this Court is not duty-bound to analyze and weigh all over again the evidence already considered in the proceedings below.  This rule, however, is not without exceptions." The findings of fact of the Court of Appeals, which are as a general rule deemed conclusive, may admit of review by this Court:
2010-07-05
VELASCO JR., J.
In deciding this appeal, the Court once again reiterates the legal aphorism that factual findings of the Court of Appeals affirming those of the trial court are binding on this Court unless there is a clear showing that such findings are tainted with arbitrariness, capriciousness or palpable error.[30] Unfortunately, however, accused-appellant failed to show any of these as to warrant a review of the findings of fact of the lower courts.
2010-06-29
VELASCO JR., J.
In this regard, it should be noted that questions concerning the credibility of a witness are best addressed to the sound discretion of the trial court, since it is the latter which is in the best position to observe the demeanor and bodily movements of a witness.[24] This becomes all the more compelling when the appellate court affirms the findings of the trial court. Thus, we generally defer to the trial court's assessment, unless there is a clear showing that such findings are tainted with arbitrariness, capriciousness or palpable error.[25] Unfortunately, however, accused-appellant Orias failed to show any of these as to warrant a review of the findings of fact of the lower court.
2010-04-23
VELASCO JR., J.
In deciding this appeal, the Court once again reiterates the legal aphorism that factual findings of the CA affirming those of the trial court are binding on this Court unless there is a clear showing that such findings are tainted with arbitrariness, capriciousness or palpable error.[25] Unfortunately, however, accused-appellant failed to show any of these as to warrant a review of the findings of fact of the lower courts.
2009-10-28
PERALTA, J.
Findings of fact of the CA, although generally deemed conclusive, may admit review by this Court if the CA failed to notice certain relevant facts that, if properly considered, would justify a different conclusion, and if the judgment of the CA is premised on a misapprehension of facts.[20] As with the present case, the CA's observation that TCT No. 96886 is of dubious origin, as TCT No. 40043 does not appear to have been disposed of by Catalina, Isabel and Salud Lozada, is improper and constitutes an indirect attack on TCT No. 96886. As we see it, TCT No. 96886, at present, is the best proof of Joaquin Limense's ownership over Lot No. 12-C. Thus, the CA erred in ruling that respondents and petitioners co-owned Lot No. 12-C, as said lot is now registered exclusively in the name of Joaquin Limense.
2009-10-13
PERALTA, J.
Due to the foregoing findings of facts of the CA, although generally deemed conclusive, may admit review by this Court if the CA failed to notice certain relevant facts which, if properly considered, will justify a different conclusion and when the judgment of the CA is premised on misapprehension of facts.[15]
2008-10-08
LEONARDO-DE CASTRO, J.
In the alternative, petitioner further asserts that assuming the issues raised are questions of fact, this Court is still not precluded from taking cognizance of the case as the same falls within the exceptions laid in the case of Fuentes v. Court of Appeals.[13] The factual findings of the CA may be reviewed by this Court (i) when the appellate court fails to notice certain relevant facts which will justify a different conclusion; and (ii) when the findings of fact are conflicting. Petitioner points out that the appellate court erroneously concluded that the spouses of its male employees are entitled to maternity benefits on the basis of Schedule L of the CBA despite finding that there is no company practice of granting the said benefit. Petitioner adds that this finding is consistent with the finding of the DOLE that the said company practice does not exist.
2008-07-23
TINGA, J,
To begin with, this Court does not have the duty or function of weighing and sifting through the evidence presented below.  As a rule, only questions of law 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 such mode of appeal.[24]  Not one of the exceptions laid down by jurisprudence[25]  is present in this case. Moreover, findings of fact of the Court of Appeals affirming those of the trial court are accorded great respect, even finality, by this Court.[26]
2008-04-30
VELASCO JR., J.
(10) when the findings of fact of the [CA] are premised on the absence of evidence but such findings are contradicted by the evidence on record.[29]
2007-09-13
SANDOVAL-GUTIERREZ, J.
On petitioners' claim that they are the owners of Lot No. 1580, it is a well-established principle that in an appeal via a petition for review on certiorari, only questions of law may be raised.  Here, the issue posed by petitioners requires us to weigh anew the evidence submitted by the parties already passed upon by the Court of Appeals.  It is basic that this Court is not a trier of facts.  Thus, it may not review the findings of the Court of Appeals except, among others: (a) when its factual findings and those of the trial court are contradictory; (b) when its inference is manifestly mistaken or absurd; (c) when its judgment is premised on its misapprehension of the facts; and (d) when it failed to resolve relevant facts which, if properly considered, would justify a modification or reversal of the decision of the appellate court.[5]   The issue raised by petitioners that they are the actual owners of Lot No. 1580 is factual in nature and requires a review of the pieces of evidence presented by the parties.  Thus, we can no longer pass upon and evaluate the lower courts' finding that based on the evidence presented before them, specifically the result of the resurvey conducted by Engr. Romulo Unciano, respondents are "the true and lawful owners of Lot 1580."
2007-08-17
CARPIO MORALES, J.
Albeit this Court entertains factual determination of a case brought to it via Rule 45 under certain circumstances, e.g. (a) where there is grave abuse of discretion; (b) when the finding is grounded entirely on speculations, surmises or conjectures; (c) when the inference made is manifestly mistaken, absurd or impossible; (d) when the judgment of the Court of Appeals was based on a misapprehension of facts; (e) when the factual findings are themselves conflicting; (f) when the Court of Appeals, in making its findings, went beyond the issues of the case and the same are contrary to the admissions of both appellant and appellee; (g) when the Court of Appeals manifestly overlooked certain relevant facts not disputed by the parties and which, if properly considered, would justify a different conclusion; (h) where the findings of fact of the Court of Appeals are contrary to those of the trial court; (i) where the findings of fact are mere conclusions without citation of specific evidence on which they are based; and (j) where the findings of fact of the Court of Appeals are premised on the absence of evidence and are contradicted by the evidence on record,[18] the petition at bar does not present any similar or analogous circumstance.
2007-08-08
AUSTRIA-MARTINEZ, J.
Our jurisdiction under Rule 45 of the Rules of Court is limited to the review of errors of law committed by the appellate court. Generally, the findings of fact of the appellate court are deemed conclusive and we are not duty-bound to analyze and calibrate all over again the evidence adduced by the parties in the court a quo.[12] This rule, however, is not without exceptions, such as where the factual findings of the Court of Appeals and the trial court are conflicting or contradictory[13] as is obtaining in the instant case.
2007-04-13
CALLEJO, SR., J.
Third. The issues raised by petitioner require the determination of factual matters which is beyond the province of this Court. It is settled that only questions of law are entertained in petitions for review on certiorari under Rule 45 of the Rules of Court. The trial court's findings of fact, especially when affirmed by the CA, are generally binding and conclusive upon this Court. 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.[16] Unfortunately, however, petitioner 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.
2007-03-01
CARPIO, J.
As a rule, only questions of law may be appealed to the Court by petition for review. The Court is not a trier of facts, its jurisdiction being limited to errors of law.[9] Moreover, factual findings of the trial court, particularly when affirmed by the Court of Appeals, are generally binding on this Court.[10] In this case, the factual findings of the trial court and the Court of Appeals were based on substantial evidence which were not refuted with contrary proof by petitioner. We thus find no reason to disturb the factual findings of the trial court and the Court of Appeals.
2006-09-11
AUSTRIA-MARTINEZ, J.
(10) when the findings of fact of the Court of Appeals are premised on the absence of evidence but such findings are contradicted by the evidence on record. [8] (Emphasis supplied) After going over the evidence extant in the record of this case, the Court finds that the CA failed to notice a relevant fact which, if properly considered, will justify a different conclusion, thus necessitating a review of the case. Particularly, the Court is referring to the fact that there exists a material discrepancy in the technical description of Parcel 2 applied for as will be discussed forthwith.
2006-08-15
GARCIA, J.
In resolving this appeal, the Court reiterates the oft-stated doctrine that factual findings of the CA, affirmatory of those of the trial court, are binding on the Court unless there is a clear showing that such findings are tainted with arbitrariness, capriciousness or palpable error.[5]
2005-02-11
PANGANIBAN, J.
As regards Item 2, there are exceptions to the general rule barring a review of questions of fact.[19] The Court reviewed the factual findings in the present case, because the CA had manifestly overlooked certain relevant and undisputed facts which, after being considered, justified a different conclusion.[20]
2005-02-03
PANGANIBAN, J.
Section 1 of Rule 45 of the Rules of Court states that only questions of law are entertained in appeals by certiorari to the Supreme Court. However, jurisprudence has recognized several exceptions in which factual issues may be resolved by this Court:[11] (1) the legal conclusions made by the lower tribunal are speculative;[12] (2) its inferences are manifestly mistaken,[13] absurd, or impossible; (3) the lower court committed grave abuse of discretion; (4) the judgment is based on a misapprehension of facts;[14] (5) the findings of fact of the lower tribunals are conflicting;[15] (6) the CA went beyond the issues; (7) the CA's findings are contrary to the admissions of the parties;[16] (8) the CA manifestly overlooked facts not disputed which, if considered, would justify a different conclusion; (9) the findings of fact are conclusions without citation of the specific evidence on which they are based; and (10) when the findings of fact of the CA are premised on the absence of evidence but such findings are contradicted by the evidence on record.[17]
2004-08-12
CARPIO, J.
We uphold the factual findings of the trial and appellate courts. Questions of facts are beyond the pale of Rule 45 of the Rules of Court as a petition for review may only raise questions of law.[37] Moreover, factual findings of the trial court, particularly when affirmed by the Court of Appeals, are generally binding on this Court.[38] We thus find no reason to set aside the two courts' factual findings.