This case has been cited 6 times or more.
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2015-11-25 |
MENDOZA, J. |
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| It should be emphasized that, as a rule, the Court does not review factual questions under Rule 45 of the Rules of Court. In appeals from the Sandiganbayan, only questions of law and not issues of fact may be raised. Issues raised before the Court as to whether the prosecution evidence proved the guilt of the petitioners beyond reasonable doubt, or whether the presumption of innocence was properly accorded the petitioners, or whether the petitioners remained responsible for the Pag-IBIG Fund or the Home Development Mutual Fund (HDMF) remittances of the employees in March 1993 at the time of the "devolution" of the hospital are all, in varying degrees, questions of fact. Although it is true that the factual findings of the Sandiganbayan are conclusive on this Court, there are established exceptions to this rule, among them: (1) the conclusion is a finding grounded entirely on speculations, surmises, and conjectures; (2) the inference made is manifestly mistaken; (3) there is grave abuse of discretion; (4) the judgment is based on misapprehension of facts; and (5) the findings of fact of the Sandiganbayan are premised on the absence of evidence and are contradicted by evidence on record.[14] | |||||
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2015-04-22 |
MENDOZA, J. |
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| At the outset, it has been emphasized that, as a rule, the Court does not review factual questions in petitions under Rule 45 of the Rules of Court. In appeals from the Sandiganbayan decisions, only questions of law and not issues of fact may be raised. Issues on whether the prosecution evidence proved the guilt of the accused beyond reasonable doubt; whether the presumption of innocence was properly accorded the accused; whether there was sufficient evidence to support a charge of conspiracy; or whether the defense of good faith was correctly appreciated are all, in varying degrees, questions of fact.[19] As a rule, the factual findings of the Sandiganbayan are conclusive on this Court, subject to the following limited exceptions: 1] the conclusion is a finding grounded entirely on speculations, surmises, and conjectures; 2] the inference made is manifestly mistaken; 3] there is grave abuse of discretion; 4.) the judgment is based on misapprehension of facts; and 5] the findings of fact of the Sandiganbayan are premised on the absence of evidence and are contradicted by evidence on record.[20] The foregoing instances attend the case at bench. | |||||
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2014-09-24 |
MENDOZA, J. |
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| At the outset, it bears stressing that in appeals from the Sandiganbayan, as in this case, only questions of law and not questions of fact may be raised. Issues brought to the Court as to whether the prosecution was able to prove the guilt of the accused beyond reasonable doubt; or whether the presumption of innocence was sufficiently debunked; or whether or not conspiracy was satisfactorily established; or whether or not good faith was properly appreciated, are all, invariably, questions of fact.[7] | |||||
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2013-10-23 |
VILLARAMA, JR., J. |
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| Evidence is hearsay when its probative force depends on the competency and credibility of some persons other than the witness by whom it is sought to be produced. The exclusion of hearsay evidence is anchored on three reasons: (1) absence of cross-examination; (2) absence of demeanor evidence; and (3) absence of oath.[52] Basic under the rules of evidence is that a witness can only testify on facts within his or her personal knowledge. This personal knowledge is a substantive prerequisite in accepting testimonial evidence establishing the truth of a disputed fact. Corollarily, a document offered as proof of its contents has to be authenticated in the manner provided in the rules, that is, by the person with personal knowledge of the facts stated in the document.[53] | |||||
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2013-07-31 |
PERLAS-BERNABE, J. |
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| At the outset, it bears pointing out that in appeals from the Sandiganbayan, as in this case, only questions of law and not questions of fact may be raised. Issues brought to the Court on whether the prosecution was able to prove the guilt of the accused beyond reasonable doubt, whether the presumption of innocence was sufficiently debunked, whether or not conspiracy was satisfactorily established, or whether or not good faith was properly appreciated, are all, invariably, questions of fact.[20] Hence, absent any of the recognized exceptions to the above-mentioned rule,[21] the Sandiganbayan's findings on the foregoing matters should be deemed as conclusive. | |||||
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2013-07-10 |
SERENO, C.J. |
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| Nevertheless, we find the imposition of the highest range of imposable penalty in this case to be fully justified. In Jaca v. People of the Philippines,[91] promulgated on 28 January 2013, the Court convicted the very same petitioners herein of exactly the same kinds of violation of Section 3(e) of R.A. 3019 as those in the present case and imposed therein the indeterminate penalty of 12 years and 1 month as minimum to 15 years as maximum. The violations in that case arose from acts of gross inexcusable | |||||