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VALLACAR TRANSIT v. JOCELYN CATUBIG

This case has been cited 11 times or more.

2015-07-01
MENDOZA, J.
The settled rule is that only questions of law may be raised in a petition under Rule 45 of the Rules of Court. It is not this Court's function to analyze or weigh all over again the evidence already considered in the proceedings below, the Court's jurisdiction being limited to reviewing only errors of law that may have been committed by the lower court. The resolution of factual issues is the function of the lower courts, whose findings on these matters are received with respect. A question of law which the Court may pass upon must not involve an examination of the probative value of the evidence presented by the litigants.[6] This is in accordance with Section 1, Rule 45 of the Rules of Court, as amended, which reads:Section 1. Filing of petition with Supreme Court. - A party desiring to appeal by certiorari from a judgment, final order or resolution of the Court of Appeals, the Sandiganbayan, the Court of Tax Appeals, 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 may include an application for a writ of preliminary injunction or other provisional remedies and shall raise only questions of law, which must be distinctly set forth. The petitioner may seek the same provisional remedies by verified motion filed in the same action or proceeding at any time during its pendency.
2013-04-08
VELASCO JR., J.
Also, verification, like in most cases required by the rules of procedure, is a formal requirement, not jurisdictional. It is mainly intended to secure an assurance that matters which are alleged are done in good faith or are true and correct and not of mere speculation. Thus, when circumstances so warrant, as in the case at hand, "the court may simply order the correction of unverified pleadings or act on it and waive strict compliance with the rules in order that the ends of justice may thereby be served."[15]
2013-01-14
PERLAS-BERNABE, J.
In this case, it is undisputed that the proximate cause of the loss of Sps. Mamaril's vehicle was the negligent act of security guards Peña and Gaddi in allowing an unidentified person to drive out the subject vehicle. Proximate cause has been defined as that cause, which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury or loss, and without which the result would not have occurred.[15] Moreover, Peña and Gaddi failed to refute Sps. Mamaril's contention[16] that they readily admitted being at fault during the investigation that ensued.
2012-12-10
PERALTA, J.
Thus, as a rule, findings of facts of the CA are conclusive, subject to certain exceptions, to wit: (1) the factual findings of the Court of Appeals and the trial court are contradictory; (2) the findings are grounded entirely on speculation, surmises or conjectures; (3) the inference made by the Court of Appeals from its findings of fact is manifestly mistaken, absurd or impossible; (4) there is grave abuse of discretion in the appreciation of facts; (5) the appellate court, in making its findings, goes beyond the issues of the case and such findings are contrary to the admissions of both appellant and appellee; (6) the judgment of the Court of Appeals is premised on a misapprehension of facts; (7) the Court of Appeals fails to notice certain relevant facts which, if properly considered, will justify a different conclusion; and (8) the findings of fact of the Court of Appeals are contrary to those of the trial court or are mere conclusions without citation of specific evidence, or where the facts set forth by the petitioner are not disputed by respondent, or where the findings of fact of the Court of Appeals are premised on the absence of evidence but are contradicted by the evidence on record.[21] However, this Court finds that none of these exceptions are present in the instant case.
2012-12-05
VILLARAMA, JR., J.
Prefatorily, we restate the time honored principle that in a petition for review on certiorari under Rule 45 of the Rules of Court, only questions of law may be raised. Thus, in a petition for review on certiorari, the scope of the Supreme Court's judicial review is limited to reviewing only errors of law, not of fact.[84]  It is not our function to weigh all over again evidence already considered in the proceedings below, our jurisdiction is limited to reviewing only errors of law that may have been committed by the lower court.[85]
2012-11-26
MENDOZA, J.
Proximate cause is defined as that cause, which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred. And more comprehensively, the proximate legal cause is that acting first and producing the injury, either immediately or by setting other events in motion, all constituting a natural and continuous chain of events, each having a close causal connection with its immediate predecessor, the final event in the chain immediately effecting the injury as a natural and probable result of the cause which first acted, under such circumstances that the person responsible for the first event should, as an ordinary prudent and intelligent person, have reasonable ground to expect at the moment of his act or default that an injury to some person might probably result therefrom.[25]
2012-06-13
REYES, J.
First, the petition raises questions of fact which are beyond the coverage of a petition for review on certiorari.  The settled rule is that only questions of law may be raised in a petition under Rule 45 of the Rules of Court.  It is not this Court's function to analyze or weigh all over again evidence already considered in the proceedings below, our jurisdiction being limited to reviewing only errors of law that may have been committed by the lower court.  The resolution of factual issues is the function of the lower courts, whose findings on these matters are received with respect.  A question of law which we may pass upon must not involve an examination of the probative value of the evidence presented by the litigants.[12]  This is in accordance with Section 1, Rule 45 of the Rules of Court, as amended, which reads: Section 1.  Filing of petition with Supreme Court. A party desiring to appeal by certiorari from a judgment, final order or resolution of the Court of Appeals, the Sandiganbayan, the Court of Tax Appeals, 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 may include an application for a writ of preliminary injunction or other provisional remedies and shall raise only questions of law, which must be distinctly set forth.  The petitioner may seek the same provisional remedies by verified motion filed in the same action or proceeding at any time during its pendency. (Emphasis supplied)
2012-03-21
REYES, J.
First, the questions being raised by the petitioners refer to factual matters that are not proper subjects of a petition for review under Rule 45.  Settled is the rule that in a petition for review under Rule 45, only questions of law may be raised.  It is not this Court's function to analyze or weigh all over again evidence already considered in the proceedings below, our jurisdiction being limited to reviewing only errors of law that may have been committed by the lower court.  The resolution of factual issues is the function of the lower courts, whose findings on these matters are received with respect.  A question of law which we may pass upon must not involve an examination of the probative value of the evidence presented by the litigants.[17]  This is clear under Section 1, Rule 45 of the Rules of Court, as amended, which provides: Section 1. Filing of petition with Supreme Court. A party desiring to appeal by certiorari from a judgment, final order or resolution of the Court of Appeals, the Sandiganbayan, the Court of Tax Appeals, 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 may include an application for a writ of preliminary injunction or other provisional remedies and shall raise only questions of law, which must be distinctly set forth.  The petitioner may seek the same provisional remedies by verified motion filed in the same action or proceeding at any time during its pendency.  (Emphasis supplied)
2012-03-12
PERLAS-BERNABE, J.
[6] Vallacar Transit, Inc. v. Catubig, G.R. No. 175512, May 30, 2011, 649 SCRA 281.
2011-11-16
MENDOZA, J.
At the outset, it should be stressed that in a petition for review under Rule 45 of the Rules of Court, only questions of law may be raised. Thus, questions of fact are not reviewable.  It is not the Court's function to analyze or weigh all over again the evidence already considered in the proceedings below, its jurisdiction being limited to reviewing only errors of law that may have been committed by the lower court. As such, a question of law must not involve an examination of the probative value of the evidence presented by the litigants. The resolution of factual issues is the function of lower courts, whose findings on these matters are accorded respect.[27]
2011-08-24
PEREZ, J.
The issue of negligence is factual in nature.[12] And the rule, and the exceptions, is that factual findings of the Court of Appeals are generally conclusive but may be reviewed when:  (1) the factual findings of the Court of Appeals and the trial court are contradictory; (2) the findings are grounded entirely on speculation, surmises or conjectures; (3) the inference made by the Court of Appeals from its findings of fact is manifestly mistaken, absurd or impossible; (4) there is grave abuse of discretion in the appreciation of facts; (5) the appellate court, in making its findings, goes beyond the issues of the case and such findings are contrary to the admissions of both appellant and appellee; (6) the judgment of the Court of Appeals is premised on a misapprehension of facts; (7) the Court of Appeals fails to notice certain relevant facts which, if properly considered, will justify a different conclusion; and (8) the findings of fact of the Court of Appeals are contrary to those of the trial court or are mere conclusions without citation of specific evidence, or where the facts set forth by the petitioner are not disputed by respondent, or where the findings of fact of the Court of Appeals are premised on the absence of evidence but are contradicted by the evidence on record.[13]