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GR No. 174844

2013-03-20

VEVENCIA ECHIN PABALAN v. HEIRS OF SIMEON A.B. MAAMO

PEREZ, J.

For the most part, petitioners raise questions of fact which, as a general rule, are not proper subjects of appeal by certiorari under Rule 45 of the Rules of Court as this mode of appeal is confined to questions of law.[24] This Court is not a trier of facts and cannot, therefore, be tasked to go over the proofs presented by the parties in the lower courts and analyze, assess and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[25] Among the recognized exceptions to this rule, however is when the factual findings of the trial court are, as here, different from those of the CA.[26] Even then, a re-evaluation of factual issues would only be warranted when the assailed findings are totally bereft of support in the records or are so patently erroneous as to amount to grave abuse of discretion. So long as such findings are supported by the record, the findings of the Court of Appeals are conclusive and binding on this Court, even if contrary to those of the trial court.[27]

GR No. 170790

2009-10-23

ANGELITO COLMENARES v. HAND TRACTOR PARTS

QUISUMBING, J.

It is settled that questions of fact cannot be the subject of a petition for review under Rule 45 of the Rules of Court. The rule finds more stringent application where the Court of Appeals upholds the findings of fact of the trial court. In such instance, as in this case, this Court is generally bound to adopt the facts as determined by the lower courts.[20] This Court has held also that when supported by substantial evidence, the findings of fact of the Court of Appeals are conclusive and binding on the parties and are not reviewable by this Court.[21] Needless to stress, under Section 1, Rule 45 of the Rules of Court, the petition shall raise only questions of law.[22] The reason is that this Court is not a trier of facts, and is not to review and calibrate the evidence on record.[23]

GR No. 174621

2009-01-30

LA UNION CEMENT WORKERS UNION v. NLRC

TINGA, J.

Petitioner Almoite's claim is clearly a factual question which is beyond the province of a Rule 45 petition. As an overture, clear and unmistakable is the rule that the Supreme Court is not a trier of facts. Just as well entrenched is the doctrine that pure issues of fact may not be the proper subject of appeal by certiorari under Rule 45 of the Revised Rules of Court as this mode of appeal is generally confined to questions of law. We therefore take this opportunity again to reiterate that only questions of law, not questions of fact, may be raised before the Supreme Court in a petition for review under Rule 45 of the Rules of Court. This Court cannot be tasked to go over the proofs presented by the petitioners in the lower courts and analyze, assess and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[15]

GR No. 156644

2008-07-28

UNIVERSAL ROBINA SUGAR MILLING CORPORATION v. AGRIPINO CABALLEDA

NACHURA, J.

Generally, the law looks with disfavor on quitclaims and releases by employees who have been inveigled or pressured into signing them by unscrupulous employers seeking to evade their legal responsibilities and frustrate just claims of employees.[32] They are frowned upon as contrary to public policy. A quitclaim is ineffective in barring recovery of the full measure of a worker's rights, and the acceptance of benefits therefrom does not amount to estoppel.[33]

GR No. 176478

2008-02-04

LORNA A. MEDINA v. COA

TINGA, J,

Unfazed, petitioner now asks this Court to once again review the factual findings and conclusions of the Deputy Ombudsman which had already been affirmed by the Court of Appeals. Whether the finding of petitioner's guilt for grave misconduct and dishonesty is supported by substantial evidence, suffice it to say these are factual issues calling for a review of the records of the case. Clear and unmistakable is the rule that the Supreme Court is not a trier of facts. Just as well entrenched is the doctrine that pure issues of fact may not be the proper subject of appeal by certiorari under Rule 45 of the Revised Rules of Court as this mode of appeal is generally confined to questions of law. Only questions of law, not questions of fact, may be raised before the Supreme Court in a petition for review under Rule 45. This Court cannot be tasked to go over the proofs presented by the petitioners in the lower courts and analyze, assess and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[31]

GR NO. 142766

2007-06-15

NARCISO AMOROSO v. JUAN ALEGRE

TINGA, J.

The RTC and the CA are one in saying that respondent had sufficiently proven his claim of ownership over the subject properties. In particular, both courts relied on the certification dated 2 July 1956 by the Bureau of Lands and the cadastral list presented by respondent that showed his predecessors-in-interest to be the owners of the subject lands. Both courts also demonstrated the weakness of the evidence presented by petitioner, pointing out that the documents he presented showed that his predecessors-in-interest were owners of the adjoining piece of land and not the properties in dispute. A reexamination of these conclusions is no longer necessary since factual issues are not the province of the Supreme Court especially in petitions for review where only questions of law may be raised. This Court cannot be tasked to go over the proofs presented by the parties in the lower courts and analyze, assess and weigh them to ascertain if the trial court and the appellate court were correct in their appreciation of the evidence.[35] Moreover, the factual findings as to the ownership of the properties reached by the trial court and affirmed by the appellate court are supported by the evidence on record and therefore should be accorded great respect.[36]

GR NO. 157919

2007-01-30

CELIA Q. NOMBREFIA v. PEOPLE

As an overture, clear and unmistakable is the rule that the Supreme Court is not a trier of facts. Just as well entrenched is the doctrine that pure issues of fact may not be the proper subject of appeal by certiorari under Rule 45 of the Revised Rules of Court as this mode of appeal is generally confined to questions of law. We therefore take this opportunity again to reiterate that only questions of law, not questions of fact, may be raised before the Supreme Court in a petition for review under Rule 45 of the Rules of Court. This Court cannot be tasked to go over the proofs presented by the petitioners in the lower courts and analyze, assess, and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[19] WHEREFORE, the petition is DENIED for lack of merit. The challenged Decision of the Court of Appeals dated May 20, 2002 and the Resolution dated March 31, 2003 denying the Motion for Reconsideration are AFFIRMED.

GR NO. 162243

2006-11-29

HEHERSON ALVAREZ SUBSTITUTED BY ELISEA G. GOZUN v. PICOP RESOURCES

CHICO-NAZARIO, J.

Finally, the DENR, by withholding the conversion of PICOP's TLA No. 43 into an IFMA, has made a factual finding that PICOP has not yet complied with the requirements for such a conversion. Findings of facts of administrative agencies are generally accorded great respect, if not finality, by the courts because of the special knowledge and expertise over matters falling under their jurisdiction.[110] Such finality of the DENR's factual finding, supported as it is by substantial evidence, can only be overcome by grave abuse of discretion amounting to lack or excess in jurisdiction, which is even more pronounced in a Petition for Mandamus.

GR NO. 140086

2005-06-08

TEOVILLE HOMEOWNERS ASSOCIATION v. EDWARD L. FERREIRA

CHICO-NAZARIO, J.

Finally, on the issue of substance, a less stringent interpretation of the rules is not justified in the instant case which raises factual issues already passed upon by both the HLURB and the Office of the President. Findings of fact by administrative agencies are generally accorded great respect, if not finality, by the Court because of the special knowledge and expertise over matters falling under their jurisdiction.[37]

GR No. 147473

2004-03-30

ACD INVESTIGATION SECURITY AGENCY v. PABLO D. DAQUERA

SANDOVAL-GUTIERREZ, J.

One final note. We hold that the Court of Appeals did not err when it affirmed the award of monetary benefits to respondent despite his quitclaim. In JMM Promotions and Management, Inc. vs. Court of Appeals,[10] we held that "quitclaims, waivers and/or complete releases executed by employees do not stop them from pursuing their claims - if there is a showing of undue pressure or duress. The basic reason for this is that such quitclaims, waivers and/or complete releases, being figuratively exacted through the barrel of a gun, are against public policy and therefore null and void ab initio. Accordingly, respondent's signature in the subject waiver or quitclaim, as in this case, never foreclosed his right to pursue a case for money claim."

	GR No. 174844 2013-03-20	VEVENCIA ECHIN PABALAN v. HEIRS OF SIMEON A.B. MAAMO PEREZ, J.
For the most part, petitioners raise questions of fact which, as a general rule, are not proper subjects of appeal by certiorari under Rule 45 of the Rules of Court as this mode of appeal is confined to questions of law.[24] This Court is not a trier of facts and cannot, therefore, be tasked to go over the proofs presented by the parties in the lower courts and analyze, assess and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[25] Among the recognized exceptions to this rule, however is when the factual findings of the trial court are, as here, different from those of the CA.[26] Even then, a re-evaluation of factual issues would only be warranted when the assailed findings are totally bereft of support in the records or are so patently erroneous as to amount to grave abuse of discretion. So long as such findings are supported by the record, the findings of the Court of Appeals are conclusive and binding on this Court, even if contrary to those of the trial court.[27]
	GR No. 170790 2009-10-23	ANGELITO COLMENARES v. HAND TRACTOR PARTS QUISUMBING, J.
It is settled that questions of fact cannot be the subject of a petition for review under Rule 45 of the Rules of Court. The rule finds more stringent application where the Court of Appeals upholds the findings of fact of the trial court. In such instance, as in this case, this Court is generally bound to adopt the facts as determined by the lower courts.[20] This Court has held also that when supported by substantial evidence, the findings of fact of the Court of Appeals are conclusive and binding on the parties and are not reviewable by this Court.[21] Needless to stress, under Section 1, Rule 45 of the Rules of Court, the petition shall raise only questions of law.[22] The reason is that this Court is not a trier of facts, and is not to review and calibrate the evidence on record.[23]
	GR No. 174621 2009-01-30	LA UNION CEMENT WORKERS UNION v. NLRC TINGA, J.
Petitioner Almoite's claim is clearly a factual question which is beyond the province of a Rule 45 petition. As an overture, clear and unmistakable is the rule that the Supreme Court is not a trier of facts. Just as well entrenched is the doctrine that pure issues of fact may not be the proper subject of appeal by certiorari under Rule 45 of the Revised Rules of Court as this mode of appeal is generally confined to questions of law. We therefore take this opportunity again to reiterate that only questions of law, not questions of fact, may be raised before the Supreme Court in a petition for review under Rule 45 of the Rules of Court. This Court cannot be tasked to go over the proofs presented by the petitioners in the lower courts and analyze, assess and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[15]
	GR No. 156644 2008-07-28	UNIVERSAL ROBINA SUGAR MILLING CORPORATION v. AGRIPINO CABALLEDA NACHURA, J.
Generally, the law looks with disfavor on quitclaims and releases by employees who have been inveigled or pressured into signing them by unscrupulous employers seeking to evade their legal responsibilities and frustrate just claims of employees.[32] They are frowned upon as contrary to public policy. A quitclaim is ineffective in barring recovery of the full measure of a worker's rights, and the acceptance of benefits therefrom does not amount to estoppel.[33]
	GR No. 176478 2008-02-04	LORNA A. MEDINA v. COA TINGA, J,
Unfazed, petitioner now asks this Court to once again review the factual findings and conclusions of the Deputy Ombudsman which had already been affirmed by the Court of Appeals. Whether the finding of petitioner's guilt for grave misconduct and dishonesty is supported by substantial evidence, suffice it to say these are factual issues calling for a review of the records of the case. Clear and unmistakable is the rule that the Supreme Court is not a trier of facts. Just as well entrenched is the doctrine that pure issues of fact may not be the proper subject of appeal by certiorari under Rule 45 of the Revised Rules of Court as this mode of appeal is generally confined to questions of law. Only questions of law, not questions of fact, may be raised before the Supreme Court in a petition for review under Rule 45. This Court cannot be tasked to go over the proofs presented by the petitioners in the lower courts and analyze, assess and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[31]
	GR NO. 142766 2007-06-15	NARCISO AMOROSO v. JUAN ALEGRE TINGA, J.
The RTC and the CA are one in saying that respondent had sufficiently proven his claim of ownership over the subject properties. In particular, both courts relied on the certification dated 2 July 1956 by the Bureau of Lands and the cadastral list presented by respondent that showed his predecessors-in-interest to be the owners of the subject lands. Both courts also demonstrated the weakness of the evidence presented by petitioner, pointing out that the documents he presented showed that his predecessors-in-interest were owners of the adjoining piece of land and not the properties in dispute. A reexamination of these conclusions is no longer necessary since factual issues are not the province of the Supreme Court especially in petitions for review where only questions of law may be raised. This Court cannot be tasked to go over the proofs presented by the parties in the lower courts and analyze, assess and weigh them to ascertain if the trial court and the appellate court were correct in their appreciation of the evidence.[35] Moreover, the factual findings as to the ownership of the properties reached by the trial court and affirmed by the appellate court are supported by the evidence on record and therefore should be accorded great respect.[36]
	GR NO. 157919 2007-01-30	CELIA Q. NOMBREFIA v. PEOPLE
As an overture, clear and unmistakable is the rule that the Supreme Court is not a trier of facts. Just as well entrenched is the doctrine that pure issues of fact may not be the proper subject of appeal by certiorari under Rule 45 of the Revised Rules of Court as this mode of appeal is generally confined to questions of law. We therefore take this opportunity again to reiterate that only questions of law, not questions of fact, may be raised before the Supreme Court in a petition for review under Rule 45 of the Rules of Court. This Court cannot be tasked to go over the proofs presented by the petitioners in the lower courts and analyze, assess, and weigh them to ascertain if the court a quo and the appellate court were correct in their appreciation of the evidence.[19] WHEREFORE, the petition is DENIED for lack of merit. The challenged Decision of the Court of Appeals dated May 20, 2002 and the Resolution dated March 31, 2003 denying the Motion for Reconsideration are AFFIRMED.
	GR NO. 162243 2006-11-29	HEHERSON ALVAREZ SUBSTITUTED BY ELISEA G. GOZUN v. PICOP RESOURCES CHICO-NAZARIO, J.
Finally, the DENR, by withholding the conversion of PICOP's TLA No. 43 into an IFMA, has made a factual finding that PICOP has not yet complied with the requirements for such a conversion. Findings of facts of administrative agencies are generally accorded great respect, if not finality, by the courts because of the special knowledge and expertise over matters falling under their jurisdiction.[110] Such finality of the DENR's factual finding, supported as it is by substantial evidence, can only be overcome by grave abuse of discretion amounting to lack or excess in jurisdiction, which is even more pronounced in a Petition for Mandamus.
	GR NO. 140086 2005-06-08	TEOVILLE HOMEOWNERS ASSOCIATION v. EDWARD L. FERREIRA CHICO-NAZARIO, J.
Finally, on the issue of substance, a less stringent interpretation of the rules is not justified in the instant case which raises factual issues already passed upon by both the HLURB and the Office of the President. Findings of fact by administrative agencies are generally accorded great respect, if not finality, by the Court because of the special knowledge and expertise over matters falling under their jurisdiction.[37]
	GR No. 147473 2004-03-30	ACD INVESTIGATION SECURITY AGENCY v. PABLO D. DAQUERA SANDOVAL-GUTIERREZ, J.
One final note. We hold that the Court of Appeals did not err when it affirmed the award of monetary benefits to respondent despite his quitclaim. In JMM Promotions and Management, Inc. vs. Court of Appeals,[10] we held that "quitclaims, waivers and/or complete releases executed by employees do not stop them from pursuing their claims - if there is a showing of undue pressure or duress. The basic reason for this is that such quitclaims, waivers and/or complete releases, being figuratively exacted through the barrel of a gun, are against public policy and therefore null and void ab initio. Accordingly, respondent's signature in the subject waiver or quitclaim, as in this case, never foreclosed his right to pursue a case for money claim."

JMM PROMOTIONS v. CA