Lawyerly

GR No. 193100

2014-12-10

VILLARAMA, JR., J.

ATTY. FRANCIA: Q: Did the petitioner file an accurate Return? MS. RAPATAN: A: No. ATTY. FRANCIA: Q: Can you please explain? MS. RAPATAN: A: Because I based the computation of my deficiency withholding taxes on declared taxable income per alpha list submitted then, I have extracted a data from the Alpha List, particularly that of the manager and other officials, only their basic salary and their overtime pay were declared but the other benefits were not actually subjected to withholding tax. So, the deficiency withholding taxes from the taxes on the taxable 13th month pay and other benefits in excess of the [P]12,000.00 for 1997 and for the taxable years 1998 and 1999, in excess of the [P]30,000.00. I also noticed that the per diem of the Manager was not included in the withholding tax computation of SAMELCO[-]I. ATTY. FRANCIA: Nothing further, your Honors. JUSTICE BAUTISTA: Any re-cross? ATTY. NAPUTO: No re-cross, your Honors.[15] We have consistently held that courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under its special and technical training and knowledge.[16] The findings of fact of these quasi-judicial agencies are generally accorded respect and even finality as long as they are supported by substantial evidence in recognition of their expertise on the specific matters under their consideration.[17] In the case at bar, petitioner failed to proffer convincing argument and evidence that would persuade us to disturb the factual findings of the CTA First Division, as affirmed by the CTA EB. As such, we cannot but affirm the finding of petitioner's substantial underdeclaration of withholding taxes in the amount of P2,690,850.91 which constituted the "falsity" in the subject returns.

GR No. 201781

2014-12-10

ANNIE GERONIMO v. SPS. ESTELA C. CALDERON AND RODOLFO T. CALDERON

VILLARAMA, JR., J.

In fine, we agree with the rulings of the HLURB, OP and the CA that respondents are entitled to the relief sought. Well-entrenched is the rule that courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under the special and technical training and knowledge of such agency.[23] Administrative agencies are given a wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions, latitude which includes the authority to take judicial notice of facts within their special competence.[24]

GR No. 178110

2011-06-15

AYALA LAND v. SIMEONA CASTILLO

SERENO, J.

Courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under its special and technical training and knowledgeand the latter are given wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions. [29] This Court has always given primary importance to the DAR Secretary's ruling and will not disturb such ruling without substantial reason: Considering that these issues involve an evaluation of the DAR's findings of facts, this Court is constrained to accord respect to such findings. It is settled that factual findings of administrative agencies are generally accorded respect and even finality by this Court, if such findings are supported by substantial evidence. The factual findings of the Secretary of DAR who, by reason of his official position, has acquired expertise in specific matters within his jurisdiction, deserve full respect and, without justifiable reason, ought not to be altered, modified or reversed.[30]

GR No. 159588

2010-09-15

P & CHIEF SUPERINTENDENT ROBERTO L. CALINISAN v. SPO2 REYNALDO ROAQUIN Y LADERAS

ABAD, J.

Two. Besides, the petition has no merit. R.A. 6975,[17] which took effect on January 1, 1991, provides the procedural framework for administrative actions against erring police officers. Sections 41 and 42 grant concurrent jurisdiction to the People's Law Enforcement Board, on the one hand, and the PNP Chief and regional directors, on the other, over administrative charges against police officers that are subject to dismissal.[18]

GR No. 182248

2008-12-18

EQUITABLE PCI BANKING CORPORATION v. RCBC CAPITAL CORPORATION

VELASCO JR., J.

In resolving administrative cases, conduct of full-blown trial is not indispensable to dispense justice to the parties. The requirement of notice and hearing does not connote full adversarial proceedings. Submission of position papers may be sufficient for as long as the parties thereto are given the opportunity to be heard. In administrative proceedings, the essence of due process is simply an opportunity to be heard, or an opportunity to explain one's side or opportunity to seek a reconsideration of the action or ruling complained of. This constitutional mandate is deemed satisfied if a person is granted an opportunity to seek reconsideration of an action or a ruling. It does not require trial-type proceedings similar to those in the courts of justice. Where opportunity to be heard either through oral arguments or through pleadings is accorded, there is no denial of procedural due process.[67] (Emphasis supplied.)

GR No. 161910

2008-06-17

DEPARTMENT OF AGRARIAN REFORM v. MA. REGINA I. SAMSON

YNARES-SATIAGO, J.

Courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under the special and technical training and knowledge of such agency. Administrative agencies are given wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions, latitude which includes the authority to take judicial notice of facts within their special competence.[32]

GR NO. 154243

2007-12-04

DEPUTY DIRECTOR GENERAL ROBERTO LASTIMOSO v. P & SENIOR INSPECTOR JOSE J. ASAYO

AUSTRIA-MARTINEZ, J.

It was only in Quiambao v. Court of Appeals,[7] promulgated in 2005 or after respondent had already filed the petition for certiorari with the trial court, when the Court resolved the issue of which body has jurisdiction over cases that fall under both Sections 41 and 42 of R.A. No. 6975. The Court held that the PLEB and the PNP Chief and regional directors have concurrent jurisdiction over administrative cases filed against members of the PNP which may warrant dismissal from service, but once a complaint is filed with the PNP Chief or regional directors, said authorities shall acquire exclusive original jurisdiction over the case.

GR No. 158460

2007-08-24

PFIZER v. EDWIN V. GALAN

SANDOVAL-GUTIERREZ, J.

There are two (2) jurisprudential rules of long-standing in this jurisdiction. First, is the hoary rule that factual issues are beyond the scope of certiorari as they do not involve any jurisdictional issue.[7] As held by this Court in Quiambao v. Court of Appeals,[8] in certiorari proceedings under Rule 65, questions of fact are not generally permitted, the inquiry being limited essentially to whether or not the respondent tribunal acted without or in excess of its jurisdiction. Second, is the cardinal principle that factual findings of the NLRC affirming those of the Labor Arbiter, when devoid of any unfairness or arbitrariness, are accorded respect if not finality by the Court of Appeals.[9] And where the findings of the Labor Arbiter are affirmed by the NLRC and the Court of Appeals, these are deemed binding, final, and conclusive upon the Supreme Court.[10] It is not the function of the Supreme Court to inquire into the correctness of the evaluation of the evidence which was the basis for the labor official's ruling. And this Court may not disturb the findings of facts of those officials who have gained expertise in their specialized field, where such findings have been given the stamp of approval by the Court of Appeals.

GR NO. 171048

2007-07-31

RUDY A. PALECPEC v. CORAZON C. DAVIS IN HER CAPACITY AS REGIONAL EXECUTIVE DIRECTOR

PER CURIAM

[T]he disputed Memorandum (sic) by Davis are flawed simply because it failed to serve it to [petitioner] x x x. Be it noted that no iota of proof has been adduced that [petitioner] has received either of said disputed Memorandum.[23] Petitioner brought his case before us via an appeal by certiorari from the adverse Decision and Resolution of the Court of Appeals. In a long line of cases, it has been held that the Supreme Court is not a trier of facts; and under Rule 45 of the 1997 Rules of Civil Procedure, a petition for review to be given due course should raise only questions of law.[24]

GR NO. 163235

2007-04-27

VIVA FOOTWEAR MANUFACTURING CORPORATION v. SECURITIES

QUISUMBING, J.

In administrative proceedings such as the instant case, only substantial evidence or that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion is required. Thus, findings of fact of quasi-judicial agencies are generally accorded respect and even finality by this Court, if supported by substantial evidence, in recognition of their expertise on the specific matters under their consideration.[22]

GR NO. 154243

2007-03-06

DEPUTY DIRECTOR GENERAL ROBERTO LASTIMOSO v. P & SENIOR INSPECTOR JOSE J. ASAYO

AUSTRIA-MARTINEZ, J.

The Court has previously ruled on this issue in Quiambao v. Court of Appeals,[7] to wit:Republic Act (R.A.) No. 6975 or the Department of the Interior and Local Government Act of 1990, which took effect on 1 January 1991, x x x delineates the procedural framework in pursuing administrative complaints against erring members of the police organization. Section 41 of the law enumerates the authorities to which a complaint against an erring member of the PNP may be filed, thus;

GR NO. 171063

2007-03-02

vs. v. COMELEC

SANDOVAL-GUTIERREZ, J.

In certiorari proceedings, questions of fact are not generally permitted, the inquiry being limited essentially to whether or not the respondent tribunal had acted without or in excess of its jurisdiction or with grave abuse of discretion.[7] Here, petitioner is questioning respondent COMELEC's conclusion that there is a "tie between the two candidates." Definitely, this is a factual issue.

GR NO. 164588

2005-10-19

NAUTICA CANNING CORPORATION v. ROBERTO C. YUMUL

YNARES-SANTIAGO, J.

We see no cogent reason to set aside the factual findings of the SEC, as upheld by the Court of Appeals. Findings of fact of quasi-judicial agencies, like the SEC, are generally accorded respect and even finality by the Supreme Court, if supported by substantial evidence, in recognition of their expertise on the specific matters under their consideration,[20] moreso if the same has been upheld by the appellate court, as in this case.

	GR No. 193100 2014-12-10	SAMAR-I ELECTRIC COOPERATIVE v. CIR VILLARAMA, JR., J.
ATTY. FRANCIA: Q: Did the petitioner file an accurate Return? MS. RAPATAN: A: No. ATTY. FRANCIA: Q: Can you please explain? MS. RAPATAN: A: Because I based the computation of my deficiency withholding taxes on declared taxable income per alpha list submitted then, I have extracted a data from the Alpha List, particularly that of the manager and other officials, only their basic salary and their overtime pay were declared but the other benefits were not actually subjected to withholding tax. So, the deficiency withholding taxes from the taxes on the taxable 13th month pay and other benefits in excess of the [P]12,000.00 for 1997 and for the taxable years 1998 and 1999, in excess of the [P]30,000.00. I also noticed that the per diem of the Manager was not included in the withholding tax computation of SAMELCO[-]I. ATTY. FRANCIA: Nothing further, your Honors. JUSTICE BAUTISTA: Any re-cross? ATTY. NAPUTO: No re-cross, your Honors.[15] We have consistently held that courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under its special and technical training and knowledge.[16] The findings of fact of these quasi-judicial agencies are generally accorded respect and even finality as long as they are supported by substantial evidence in recognition of their expertise on the specific matters under their consideration.[17] In the case at bar, petitioner failed to proffer convincing argument and evidence that would persuade us to disturb the factual findings of the CTA First Division, as affirmed by the CTA EB. As such, we cannot but affirm the finding of petitioner's substantial underdeclaration of withholding taxes in the amount of P2,690,850.91 which constituted the "falsity" in the subject returns.
	GR No. 201781 2014-12-10	ANNIE GERONIMO v. SPS. ESTELA C. CALDERON AND RODOLFO T. CALDERON VILLARAMA, JR., J.
In fine, we agree with the rulings of the HLURB, OP and the CA that respondents are entitled to the relief sought. Well-entrenched is the rule that courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under the special and technical training and knowledge of such agency.[23] Administrative agencies are given a wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions, latitude which includes the authority to take judicial notice of facts within their special competence.[24]
	GR No. 178110 2011-06-15	AYALA LAND v. SIMEONA CASTILLO SERENO, J.
Courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under its special and technical training and knowledgeand the latter are given wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions. [29] This Court has always given primary importance to the DAR Secretary's ruling and will not disturb such ruling without substantial reason: Considering that these issues involve an evaluation of the DAR's findings of facts, this Court is constrained to accord respect to such findings. It is settled that factual findings of administrative agencies are generally accorded respect and even finality by this Court, if such findings are supported by substantial evidence. The factual findings of the Secretary of DAR who, by reason of his official position, has acquired expertise in specific matters within his jurisdiction, deserve full respect and, without justifiable reason, ought not to be altered, modified or reversed.[30]
	GR No. 159588 2010-09-15	P & CHIEF SUPERINTENDENT ROBERTO L. CALINISAN v. SPO2 REYNALDO ROAQUIN Y LADERAS ABAD, J.
Two. Besides, the petition has no merit. R.A. 6975,[17] which took effect on January 1, 1991, provides the procedural framework for administrative actions against erring police officers. Sections 41 and 42 grant concurrent jurisdiction to the People's Law Enforcement Board, on the one hand, and the PNP Chief and regional directors, on the other, over administrative charges against police officers that are subject to dismissal.[18]
	GR No. 182248 2008-12-18	EQUITABLE PCI BANKING CORPORATION v. RCBC CAPITAL CORPORATION VELASCO JR., J.
In resolving administrative cases, conduct of full-blown trial is not indispensable to dispense justice to the parties. The requirement of notice and hearing does not connote full adversarial proceedings. Submission of position papers may be sufficient for as long as the parties thereto are given the opportunity to be heard. In administrative proceedings, the essence of due process is simply an opportunity to be heard, or an opportunity to explain one's side or opportunity to seek a reconsideration of the action or ruling complained of. This constitutional mandate is deemed satisfied if a person is granted an opportunity to seek reconsideration of an action or a ruling. It does not require trial-type proceedings similar to those in the courts of justice. Where opportunity to be heard either through oral arguments or through pleadings is accorded, there is no denial of procedural due process.[67] (Emphasis supplied.)
	GR No. 161910 2008-06-17	DEPARTMENT OF AGRARIAN REFORM v. MA. REGINA I. SAMSON YNARES-SATIAGO, J.
Courts will not interfere in matters which are addressed to the sound discretion of the government agency entrusted with the regulation of activities coming under the special and technical training and knowledge of such agency. Administrative agencies are given wide latitude in the evaluation of evidence and in the exercise of their adjudicative functions, latitude which includes the authority to take judicial notice of facts within their special competence.[32]
	GR NO. 154243 2007-12-04	DEPUTY DIRECTOR GENERAL ROBERTO LASTIMOSO v. P & SENIOR INSPECTOR JOSE J. ASAYO AUSTRIA-MARTINEZ, J.
It was only in Quiambao v. Court of Appeals,[7] promulgated in 2005 or after respondent had already filed the petition for certiorari with the trial court, when the Court resolved the issue of which body has jurisdiction over cases that fall under both Sections 41 and 42 of R.A. No. 6975. The Court held that the PLEB and the PNP Chief and regional directors have concurrent jurisdiction over administrative cases filed against members of the PNP which may warrant dismissal from service, but once a complaint is filed with the PNP Chief or regional directors, said authorities shall acquire exclusive original jurisdiction over the case.
	GR No. 158460 2007-08-24	PFIZER v. EDWIN V. GALAN SANDOVAL-GUTIERREZ, J.
There are two (2) jurisprudential rules of long-standing in this jurisdiction. First, is the hoary rule that factual issues are beyond the scope of certiorari as they do not involve any jurisdictional issue.[7] As held by this Court in Quiambao v. Court of Appeals,[8] in certiorari proceedings under Rule 65, questions of fact are not generally permitted, the inquiry being limited essentially to whether or not the respondent tribunal acted without or in excess of its jurisdiction. Second, is the cardinal principle that factual findings of the NLRC affirming those of the Labor Arbiter, when devoid of any unfairness or arbitrariness, are accorded respect if not finality by the Court of Appeals.[9] And where the findings of the Labor Arbiter are affirmed by the NLRC and the Court of Appeals, these are deemed binding, final, and conclusive upon the Supreme Court.[10] It is not the function of the Supreme Court to inquire into the correctness of the evaluation of the evidence which was the basis for the labor official's ruling. And this Court may not disturb the findings of facts of those officials who have gained expertise in their specialized field, where such findings have been given the stamp of approval by the Court of Appeals.
	GR NO. 171048 2007-07-31	RUDY A. PALECPEC v. CORAZON C. DAVIS IN HER CAPACITY AS REGIONAL EXECUTIVE DIRECTOR PER CURIAM
[T]he disputed Memorandum (sic) by Davis are flawed simply because it failed to serve it to [petitioner] x x x. Be it noted that no iota of proof has been adduced that [petitioner] has received either of said disputed Memorandum.[23] Petitioner brought his case before us via an appeal by certiorari from the adverse Decision and Resolution of the Court of Appeals. In a long line of cases, it has been held that the Supreme Court is not a trier of facts; and under Rule 45 of the 1997 Rules of Civil Procedure, a petition for review to be given due course should raise only questions of law.[24]
	GR NO. 163235 2007-04-27	VIVA FOOTWEAR MANUFACTURING CORPORATION v. SECURITIES QUISUMBING, J.
In administrative proceedings such as the instant case, only substantial evidence or that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion is required. Thus, findings of fact of quasi-judicial agencies are generally accorded respect and even finality by this Court, if supported by substantial evidence, in recognition of their expertise on the specific matters under their consideration.[22]
	GR NO. 154243 2007-03-06	DEPUTY DIRECTOR GENERAL ROBERTO LASTIMOSO v. P & SENIOR INSPECTOR JOSE J. ASAYO AUSTRIA-MARTINEZ, J.
The Court has previously ruled on this issue in Quiambao v. Court of Appeals,[7] to wit:Republic Act (R.A.) No. 6975 or the Department of the Interior and Local Government Act of 1990, which took effect on 1 January 1991, x x x delineates the procedural framework in pursuing administrative complaints against erring members of the police organization. Section 41 of the law enumerates the authorities to which a complaint against an erring member of the PNP may be filed, thus;
	GR NO. 171063 2007-03-02	vs. v. COMELEC SANDOVAL-GUTIERREZ, J.
In certiorari proceedings, questions of fact are not generally permitted, the inquiry being limited essentially to whether or not the respondent tribunal had acted without or in excess of its jurisdiction or with grave abuse of discretion.[7] Here, petitioner is questioning respondent COMELEC's conclusion that there is a "tie between the two candidates." Definitely, this is a factual issue.
	GR NO. 164588 2005-10-19	NAUTICA CANNING CORPORATION v. ROBERTO C. YUMUL YNARES-SANTIAGO, J.
We see no cogent reason to set aside the factual findings of the SEC, as upheld by the Court of Appeals. Findings of fact of quasi-judicial agencies, like the SEC, are generally accorded respect and even finality by the Supreme Court, if supported by substantial evidence, in recognition of their expertise on the specific matters under their consideration,[20] moreso if the same has been upheld by the appellate court, as in this case.

FELINO QUIAMBAO v. CA