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CHINA BANKING CORPORATION v. QBRO FISHING ENTERPRISES

This case has been cited 2 times or more.

2014-08-27
DEL CASTILLO, J.
Time and again, this Court has reiterated that it is not a trier of facts.  Well entrenched is the principle that factual findings of the trial court, when adopted and confirmed by the CA, are final and conclusive and may not be reviewed on appeal by this Court.[56]  The Court's "role in a petition under Rule 45 is limited to reviewing or reversing errors of law allegedly committed by the appellate court."[57]  This rule, however, is not without well defined exceptions.  "Findings of fact of the trial court and the CA may be set aside when such findings are not supported by the evidence or where the lower courts' conclusions are based on a misapprehension of facts."[58] Considering the contention of petitioners that misinterpretation of facts was committed, this Court embarked on the task of reviewing the facts of this case.
2014-03-12
VILLARAMA, JR., J.
Prefatorily, we address the issue raised by respondent that only questions of law may be raised in a petition for review on certiorari.  Indeed, the principle is well established that this Court is not a trier of facts.  Therefore, in an appeal by certiorari under Rule 45 of the 1997 Rules of Civil Procedure, as amended, only questions of law may be raised.[28]  The distinction between a "question of law" and a "question of fact" is settled.  There is a question of law when the doubt or difference arises as to what the law is on a certain state of facts, and the question does not call for an examination of the probative value of the evidence presented by the parties-litigants.  On the other hand, there is a "question of fact" when the doubt or controversy arises as to the truth or falsity of the alleged facts.  Simply put, when there is no dispute as to the facts, the question of whether the conclusion drawn therefrom is correct or not, is a question of law.[29]  In Republic v. Vega,[30] the Court held that when petitioner asks for a review of the decision made by a lower court based on the evidence presented, without delving into their probative value but simply on their sufficiency to support the legal conclusions made, then a question of law is raised.