This case has been cited 8 times or more.
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2015-08-03 |
DEL CASTILLO, J. |
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| A petition to review the decision of the CA is not a matter of right but of sound judicial discretion.[21] It has been repeatedly held that the jurisdiction of this Court in cases brought before it from the CA is limited to reviewing errors of law; findings of fact of the appellate court are conclusive upon this Court, as it is not its function to analyze and weigh the evidence all over again. There are recognized exceptions to the rule, however, such as: (1) when the findings are grounded entirely on speculations, surmises or conjectures; (2) when the inference made is manifestly mistaken, absurd or impossible; (3) when there is grave abuse of discretion; (4) when the judgment is based on a misapprehension of facts; (5) when the findings of fact are conflicting; (6) when in making its findings the CA went beyond the issues of the case, or its findings are contrary to the admissions of both the appellant and the appellee; (7) when the findings are contrary to those of the trial court; (8) when the findings are conclusions without citation of specific evidence on which they are based; (9) when the facts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondent; (10) when the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; or (11) when the CA manifestly overlooked certain relevant facts not disputed by the parties, which, if properly considered, would justify a different conclusion.[22] | |||||
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2014-09-09 |
BERSAMIN, J. |
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| The constitutionality of the minute resolutions was the issue raised in Komatsu Industries (Phils.), Inc. v. Court of Appeals.[28] The petitioner contended that the minute resolutions violated Section 14,[29] Article VIII of the Constitution. The Court, through Justice Regalado, declared that resolutions were not decisions within the constitutional contemplation, for the former "merely hold that the petition for review should not be entertained and even ordinary lawyers have all this time so understood it; and the petition to review the decision of the Court of Appeals is not a matter of right but of sound judicial discretion, hence there is no need to fully explain the Court's denial since, for one thing, the facts and the law are already mentioned in the Court of Appeal's decision." It pointed out that the constitutional mandate was applicable only in cases submitted for decision, i.e., given due course to and after the filing of briefs or memoranda and/or other pleadings, but not where the petition was being refused due course, with the resolutions for that purpose stating the legal basis of the refusal. Thus, when the Court, after deliberating on the petition and the subsequent pleadings, decided to deny due course to the petition and stated that the questions raised were factual, or there was no reversible error in the lower court's decision, there was a sufficient compliance with the constitutional requirement.[30] | |||||
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2014-09-09 |
BERSAMIN, J. |
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| The constitutionality of the minute resolutions was the issue raised in Komatsu Industries (Phils.), Inc. v. Court of Appeals.[28] The petitioner contended that the minute resolutions violated Section 14,[29] Article VIII of the Constitution. The Court, through Justice Regalado, declared that resolutions were not decisions within the constitutional contemplation, for the former "merely hold that the petition for review should not be entertained and even ordinary lawyers have all this time so understood it; and the petition to review the decision of the Court of Appeals is not a matter of right but of sound judicial discretion, hence there is no need to fully explain the Court's denial since, for one thing, the facts and the law are already mentioned in the Court of Appeal's decision." It pointed out that the constitutional mandate was applicable only in cases submitted for decision, i.e., given due course to and after the filing of briefs or memoranda and/or other pleadings, but not where the petition was being refused due course, with the resolutions for that purpose stating the legal basis of the refusal. Thus, when the Court, after deliberating on the petition and the subsequent pleadings, decided to deny due course to the petition and stated that the questions raised were factual, or there was no reversible error in the lower court's decision, there was a sufficient compliance with the constitutional requirement.[30] | |||||
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2009-01-20 |
CARPIO MORALES, J. |
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| In its separate Comment,[17] SLDC argues that the present petition, insofar as the Pasong Tamo property is concerned, is barred by res judicata, the Court in Komatsu Industries (Phils.) Inc. v. Philippine National Bank and Santiago Land Development Corporation and Maximo Contreras, (Komatsu case)[18] having declared PNB's extrajudicial foreclosure of the said property and eventual sale to SLDC valid. It adds that, since in G.R. No. 106194 or the "Intervention Case," it was held that a purchaser pendente lite â"€ SLDC is bound by the outcome of the case instituted by the transferor â"€ PNB, then Quisumbing, as transferee pendente lite of Komatsu's right to redeem the Pasong Tamo property, "must also necessarily be bound by the outcome of the Komatsu case" â"€ and that, perforce, "if he cannot intervene, then neither can he be allowed to file or maintain a separate case." | |||||
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2006-04-26 |
YNARES-SANTIAGO, J. |
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| At the outset, it should be stressed that the arguments raised by petitioner cannot wheedle this Court to re-examine factual matters that had already become final and executory more than a decade ago. Under the doctrine of conclusiveness of judgment which is also known as "preclusion of issues" or "collateral estoppel," issues actually and directly resolved in a former suit cannot again be raised in any future case between the same parties involving a different cause of action.[21] Once a judgment attains finality it becomes immutable and unalterable. It may no longer be modified in any respect, even if the modification is meant to correct what is perceived to be an erroneous conclusion of fact or law, and regardless of whether the modification is attempted to be made by the court rendering it or by the highest court of the land.[22] Hence, no amount of legal maneuvers could reinstate the Director of Lands' July 21, 1974 Decision which is favorable to petitioner nor set aside the Minister of Natural Resources' September 18, 1986 Decision which upheld the respondent's right and qualifications to lease the contested land. In a resolution dated July 20, 1994, we categorically held that the Court of Appeals committed no reversible error in dismissing the recourse filed by petitioner questioning the September 18, 1986 Decision of the Minister of Natural Resources. This resolution of the Court is an adjudication both on the technical issues and on the substantial issues raised, particularly on the qualification of respondent and on the validity of the award in its favor.[23] Thus, only the supervening events that would allegedly justify the suspension of the execution of the September 18, 1986 Decision of the Minister of Natural Resources will be addressed here. | |||||
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2004-06-30 |
PANGANIBAN, J. |
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| Thus, there is sufficient compliance with the constitutional requirement when a collegiate appellate court, after deliberation, decides to deny a motion; states that the questions raised are factual or have already been passed upon; or cites some other legal basis.[33] There is no need to explain fully the court's denial, since the facts and the law have already been laid out in the assailed Decision. | |||||
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2002-01-31 |
PARDO, J. |
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| Petitioners further contend that the Supreme Court's minute resolution refusing to review that decision is equivalent to a judgment on the merits. The minute resolution may amount to a final action on the case but it is not a precedent.[48] It can not bind non-parties to the action. To restate, the rule is that: (1) a judgment in rem is binding upon the whole world, such as a judgment in a land registration case or probate of a will; (2) a judgment in personam is binding upon the parties and their successors in interest but not upon strangers.[49] A judgment directing a party to deliver possession of a property to another is in personam; it is binding only against the parties and their successors in interest by title subsequent to the commencement of the action.[50] "Suits to quiet title are not technically suits in rem, nor are they, strictly speaking, in personam, but being against the person in respect of the res, these proceedings are characterized as quasi in rem. The judgment in such proceedings is conclusive only between the parties."[51] In this case, the action below is basically one for declaration of nullity of title and recovery of ownership of real property, or re-conveyance. "An action to recover a parcel of land is a real action but it is an action in personam, for it binds a particular individual only although it concerns the right to a tangible thing."[52] "Any judgment therein is binding only upon the parties properly impleaded."[53] | |||||