Lawyerly

GR No. 204644

2015-02-11

LEONEN, J.

(1) when there is grave abuse of discretion; (2) when the findings are grounded on speculations; (3) when the inference made is manifestly mistaken; (4) when the judgment of the Court of Appeals is based on a misapprehension of facts; (5) when the factual findings are conflicting; (6) when the Court of Appeals went beyond the issues of the case and its findings are contrary to the admissions of the parties; (7) when the Court of Appeals overlooked undisputed facts which, if properly considered, would justify a different conclusion; (8) when the findings of the Court of Appeals are contrary to those of the trial court; (9) when the facts set forth by the petitioner are not disputed by the respondent; and (10) when the findings of the Court of Appeals are premised on the absence of evidence and are contradicted by the evidence on record.[36]

GR No. 204755

2014-09-17

SOLEDAD TRIA v. PEOPLE

REYES, J.

Preliminarily, it bears emphasizing that factual findings of the trial court, especially when affirmed by the appellate court, are binding on and accorded great respect by this Court.[22] There are instances when this rule is not applicable such as: (1) when there is grave abuse of discretion; (2) when the findings are grounded on speculations; (3) when the inference made is manifestly mistaken; (4) when the judgment of the CA is based on a misapprehension of facts; (5) when the factual findings are conflicting; (6) when the CA went beyond the issues of the case and its findings are contrary to the admissions of the parties; (7) when the CA overlooked undisputed facts which, if properly considered, would justify a different conclusion; (8) when the findings of the CA are contrary to those of the trial court; (9) when the facts set forth by the petitioner are not disputed by the respondent; and (10) when the findings of the CA are premised on the absence of evidence and are contradicted by the evidence on record.[23]

GR No. 187268

2013-09-04

JOVITO C. PLAMERAS v. PEOPLE

PEREZ, J.

Section 1, Rule 45 of the Rules of Court states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[38] the Court held that:A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.

GR No. 163700

2012-04-18

CHARLIE JAO v. BCC PRODUCTS SALES INC.

BERSAMIN, J.

The existence of an employer-employee relationship is a question of fact. Generally, a re-examination of factual findings cannot be done by the Court acting on a petition for review on certiorari because the Court is not a trier of facts but reviews only questions of law. Nor may the Court be bound to analyze and weigh again the evidence adduced and considered in the proceedings below.[16] This rule is not absolute, however, and admits of exceptions. For one, the Court may look into factual issues in labor cases when the factual findings of the Labor Arbiter, the NLRC, and the CA are conflicting.[17]

GR No. 187887

2011-09-07

PAMELA FLORENTINA P. JUMUAD v. HI-FLYER FOOD

MENDOZA, J.

It is a hornbook rule that factual findings of administrative or quasi-judicial bodies, which are deemed to have acquired expertise in matters within their respective jurisdictions, are generally accorded not only respect but even finality, and bind the Court when supported by substantial evidence.[33] While this rule is strictly adhered to in labor cases, the same rule, however, admits exceptions. These include: (1) when there is grave abuse of discretion; (2) when the findings are grounded on speculation; (3) when the inference made is manifestly mistaken; (4) when the judgment of the Court of Appeals is based on a misapprehension of facts; (5) when the factual findings are conflicting; (6) when the Court of Appeals went beyond the issues of the case and its findings are contrary to the admissions of the parties; (7) when the Court of Appeals overlooked undisputed facts which, if properly considered, would justify a different conclusion; (8) when the facts set forth by the petitioner are not disputed by the respondent; and (9) when the findings of the Court of Appeals are premised on the absence of evidence and are contradicted by the evidence on record.[34]

GR No. 156318

2011-09-05

SPS. ANSELMO AND PRISCILLA BULAONG v. VERONICA GONZALES

BRION, J.

This rule, however, admits of several exceptions. Questions of fact may be reviewed, among others, when the lower court makes inferences that are manifestly mistaken, and when the judgment of the CA is based on a misapprehension of facts.[24] As will be apparent in the discussions below, these exceptional circumstances are present in the present case. A review of the evidence, therefore, is not only allowed, but is necessary for the proper resolution of the presented issues.

GR No. 184966

2011-05-30

HEIRS OF FELICIDAD VDA. DE DELA CRUZ NAMELY: VIOLETA DEL ROSARIO v. HEIRS OF PEDRO T. FAJARDO

CARPIO, J.

First, questions of fact are not reviewable in petitions for review on certiorari under Rule 45 of the Rules of Court. Section 1 of Rule 45 states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[12] the Court held that: A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.

GR No. 172577

2011-01-19

SOLEDAD DALTON v. FGR REALTY

CARPIO, J.

Dalton claims that the Court of Appeals erred in ruling that she failed to pay rent. The Court is not impressed. Section 1, Rule 45 of the Rules of Court states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[24] the Court held that: A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.

GR No. 178652

2010-12-08

SPS. REVELO VILLAMAR AND CORAZON PENULIAR- VILLAMAR v. PEOPLE

CARPIO, J.

Section 1, Rule 45 of the Rules of Court states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[10] the Court held that: A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.

GR No. 148974

2010-07-02

OMC CARRIERS v. SPS. ROBERTO C. NABUA AND ROSARIO T. NABUA

PERALTA, J.

A petition for review on certiorari under Rule 45 of the Rules of Court should include only questions of law questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts, while a question of fact exists when the doubt centers on the truth or falsity of the alleged facts. There is a question of law if the issue raised is capable of being resolved without need of reviewing the probative value of the evidence. Once the issue invites a review of the evidence, the question is one of fact.[14]

GR No. 174719

2010-05-05

PACRES v. HEIRS OF CECILIA YGOÑA

DEL CASTILLO, J.

Petitioners would have the Court review the evidence presented by the parties, despite the CA's finding that the trial court committed no error in appreciating the evidence presented during the trial. This goes against the rule that this Court is not a trier of facts. "Such questions as whether certain items of evidence should be accorded probative value or weight, or rejected as feeble or spurious, or whether or not the proofs on one side or the other are clear and convincing and adequate to establish a proposition in issue, are without doubt questions of fact."[36] Questions like these are not reviewable by this Court which, as a rule, confines its review of cases decided by the CA only to questions of law, which may be resolved without having to re-examine the probative value of the evidence presented.[37]

GR No. 163532

2010-03-12

YOKOHAMA TIRE PHILIPPINES v. YOKOHAMA EMPLOYEES UNION

CARPIO, J.

The Court is not convinced. A petition for review on certiorari under Rule 45 of the Rules of Court should include only questions of law -- questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts, while a question of fact exists when the doubt centers on the truth or falsity of the alleged facts. There is a question of law if the issue raised is capable of being resolved without need of reviewing the probative value of the evidence. Once the issue invites a review of the evidence, the question is one of fact.[17]

GR No. 182380

2009-08-28

ROBERT P. GUZMAN v. COMELEC

BERSAMIN, J.

The distinctions between a question of law and a question of fact are well known. There is a question of law when the doubt or difference arises as to what the law is on a certain state of facts. Such a question does not involve an examination of the probative value of the evidence presented by the litigants or any of them. But there is a question of fact when the doubt arises as to the truth or falsehood of the alleged facts or when the query necessarily invites calibration of the whole evidence, considering mainly the credibility of witnesses, existence and relevancy of specific surrounding circumstances, their relation to one another and to the whole, and the probabilities of the situation.[9]

GR No. 165907

2009-07-27

SPS. DOMINADOR R. NARVAEZ AND LILIA W. NARVAEZ v. SPS. ROSE OGAS ALCISO AND ANTONIO ALCISO

CARPIO, J.

A petition for review on certiorari under Rule 45 of the Rules of Court should include only questions of law -- questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts, while a question of fact exists when the doubt centers on the truth or falsity of the alleged facts. There is a question of law if the issue raised is capable of being resolved without need of reviewing the probative value of the evidence. Once the issue invites a review of the evidence, the question is one of fact.[17]

	GR No. 204644 2015-02-11	ANGELITA CRUZ BENITO v. PEOPLE LEONEN, J.
(1) when there is grave abuse of discretion; (2) when the findings are grounded on speculations; (3) when the inference made is manifestly mistaken; (4) when the judgment of the Court of Appeals is based on a misapprehension of facts; (5) when the factual findings are conflicting; (6) when the Court of Appeals went beyond the issues of the case and its findings are contrary to the admissions of the parties; (7) when the Court of Appeals overlooked undisputed facts which, if properly considered, would justify a different conclusion; (8) when the findings of the Court of Appeals are contrary to those of the trial court; (9) when the facts set forth by the petitioner are not disputed by the respondent; and (10) when the findings of the Court of Appeals are premised on the absence of evidence and are contradicted by the evidence on record.[36]
	GR No. 204755 2014-09-17	SOLEDAD TRIA v. PEOPLE REYES, J.
Preliminarily, it bears emphasizing that factual findings of the trial court, especially when affirmed by the appellate court, are binding on and accorded great respect by this Court.[22] There are instances when this rule is not applicable such as: (1) when there is grave abuse of discretion; (2) when the findings are grounded on speculations; (3) when the inference made is manifestly mistaken; (4) when the judgment of the CA is based on a misapprehension of facts; (5) when the factual findings are conflicting; (6) when the CA went beyond the issues of the case and its findings are contrary to the admissions of the parties; (7) when the CA overlooked undisputed facts which, if properly considered, would justify a different conclusion; (8) when the findings of the CA are contrary to those of the trial court; (9) when the facts set forth by the petitioner are not disputed by the respondent; and (10) when the findings of the CA are premised on the absence of evidence and are contradicted by the evidence on record.[23]
	GR No. 187268 2013-09-04	JOVITO C. PLAMERAS v. PEOPLE PEREZ, J.
Section 1, Rule 45 of the Rules of Court states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[38] the Court held that:A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.
	GR No. 163700 2012-04-18	CHARLIE JAO v. BCC PRODUCTS SALES INC. BERSAMIN, J.
The existence of an employer-employee relationship is a question of fact. Generally, a re-examination of factual findings cannot be done by the Court acting on a petition for review on certiorari because the Court is not a trier of facts but reviews only questions of law. Nor may the Court be bound to analyze and weigh again the evidence adduced and considered in the proceedings below.[16] This rule is not absolute, however, and admits of exceptions. For one, the Court may look into factual issues in labor cases when the factual findings of the Labor Arbiter, the NLRC, and the CA are conflicting.[17]
	GR No. 187887 2011-09-07	PAMELA FLORENTINA P. JUMUAD v. HI-FLYER FOOD MENDOZA, J.
It is a hornbook rule that factual findings of administrative or quasi-judicial bodies, which are deemed to have acquired expertise in matters within their respective jurisdictions, are generally accorded not only respect but even finality, and bind the Court when supported by substantial evidence.[33] While this rule is strictly adhered to in labor cases, the same rule, however, admits exceptions. These include: (1) when there is grave abuse of discretion; (2) when the findings are grounded on speculation; (3) when the inference made is manifestly mistaken; (4) when the judgment of the Court of Appeals is based on a misapprehension of facts; (5) when the factual findings are conflicting; (6) when the Court of Appeals went beyond the issues of the case and its findings are contrary to the admissions of the parties; (7) when the Court of Appeals overlooked undisputed facts which, if properly considered, would justify a different conclusion; (8) when the facts set forth by the petitioner are not disputed by the respondent; and (9) when the findings of the Court of Appeals are premised on the absence of evidence and are contradicted by the evidence on record.[34]
	GR No. 156318 2011-09-05	SPS. ANSELMO AND PRISCILLA BULAONG v. VERONICA GONZALES BRION, J.
This rule, however, admits of several exceptions. Questions of fact may be reviewed, among others, when the lower court makes inferences that are manifestly mistaken, and when the judgment of the CA is based on a misapprehension of facts.[24] As will be apparent in the discussions below, these exceptional circumstances are present in the present case. A review of the evidence, therefore, is not only allowed, but is necessary for the proper resolution of the presented issues.
	GR No. 184966 2011-05-30	HEIRS OF FELICIDAD VDA. DE DELA CRUZ NAMELY: VIOLETA DEL ROSARIO v. HEIRS OF PEDRO T. FAJARDO CARPIO, J.
First, questions of fact are not reviewable in petitions for review on certiorari under Rule 45 of the Rules of Court. Section 1 of Rule 45 states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[12] the Court held that: A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.
	GR No. 172577 2011-01-19	SOLEDAD DALTON v. FGR REALTY CARPIO, J.
Dalton claims that the Court of Appeals erred in ruling that she failed to pay rent. The Court is not impressed. Section 1, Rule 45 of the Rules of Court states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[24] the Court held that: A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.
	GR No. 178652 2010-12-08	SPS. REVELO VILLAMAR AND CORAZON PENULIAR- VILLAMAR v. PEOPLE CARPIO, J.
Section 1, Rule 45 of the Rules of Court states that petitions for review on certiorari "shall raise only questions of law which must be distinctly set forth." In Pagsibigan v. People,[10] the Court held that: A petition for review under Rule 45 of the Rules of Court should cover only questions of law. Questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts. A question of fact exists when the doubt centers on the truth or falsity of the alleged facts.
	GR No. 148974 2010-07-02	OMC CARRIERS v. SPS. ROBERTO C. NABUA AND ROSARIO T. NABUA PERALTA, J.
A petition for review on certiorari under Rule 45 of the Rules of Court should include only questions of law questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts, while a question of fact exists when the doubt centers on the truth or falsity of the alleged facts. There is a question of law if the issue raised is capable of being resolved without need of reviewing the probative value of the evidence. Once the issue invites a review of the evidence, the question is one of fact.[14]
	GR No. 174719 2010-05-05	PACRES v. HEIRS OF CECILIA YGOÑA DEL CASTILLO, J.
Petitioners would have the Court review the evidence presented by the parties, despite the CA's finding that the trial court committed no error in appreciating the evidence presented during the trial. This goes against the rule that this Court is not a trier of facts. "Such questions as whether certain items of evidence should be accorded probative value or weight, or rejected as feeble or spurious, or whether or not the proofs on one side or the other are clear and convincing and adequate to establish a proposition in issue, are without doubt questions of fact."[36] Questions like these are not reviewable by this Court which, as a rule, confines its review of cases decided by the CA only to questions of law, which may be resolved without having to re-examine the probative value of the evidence presented.[37]
	GR No. 163532 2010-03-12	YOKOHAMA TIRE PHILIPPINES v. YOKOHAMA EMPLOYEES UNION CARPIO, J.
The Court is not convinced. A petition for review on certiorari under Rule 45 of the Rules of Court should include only questions of law -- questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts, while a question of fact exists when the doubt centers on the truth or falsity of the alleged facts. There is a question of law if the issue raised is capable of being resolved without need of reviewing the probative value of the evidence. Once the issue invites a review of the evidence, the question is one of fact.[17]
	GR No. 182380 2009-08-28	ROBERT P. GUZMAN v. COMELEC BERSAMIN, J.
The distinctions between a question of law and a question of fact are well known. There is a question of law when the doubt or difference arises as to what the law is on a certain state of facts. Such a question does not involve an examination of the probative value of the evidence presented by the litigants or any of them. But there is a question of fact when the doubt arises as to the truth or falsehood of the alleged facts or when the query necessarily invites calibration of the whole evidence, considering mainly the credibility of witnesses, existence and relevancy of specific surrounding circumstances, their relation to one another and to the whole, and the probabilities of the situation.[9]
	GR No. 165907 2009-07-27	SPS. DOMINADOR R. NARVAEZ AND LILIA W. NARVAEZ v. SPS. ROSE OGAS ALCISO AND ANTONIO ALCISO CARPIO, J.
A petition for review on certiorari under Rule 45 of the Rules of Court should include only questions of law -- questions of fact are not reviewable. A question of law exists when the doubt centers on what the law is on a certain set of facts, while a question of fact exists when the doubt centers on the truth or falsity of the alleged facts. There is a question of law if the issue raised is capable of being resolved without need of reviewing the probative value of the evidence. Once the issue invites a review of the evidence, the question is one of fact.[17]

ROMUALDO PAGSIBIGAN v. PEOPLE