When are trial court's factual findings SC-reviewable?
The Court finds the petition bereft of merit. There is no compelling reason for the Court to disturb the findings of facts of the lower courts.
The trial court's findings are as follows: (1) Rosita failed to establish that there is an agreement between her and Arturo that the latter will give her one-third of the proceeds of the sale of the Morayta property; (2) petitioners were not able to establish by clear and sufficient evidence that the P3,000,000.00 which they took from Arturo when they encashed the subject check was part of the proceeds of the sale of the Morayta property; (3) Rosita's counterclaim is permissive and she failed to pay the full docket and filing fees for her counterclaim.
Petitioners challenge the findings of the RTC and insist that they should not be held liable for encashing the subject check because Arturo defrauded Rosita and that he committed deceitful acts which deprived her of her rightful share in the sale of her building in Morayta; that the amount of P3,000,000.00 represented by the check which they encashed formed part of the proceeds of the said sale; that Alice and Rosita were merely moved by their desire to recover from Arturo, Rosita's supposed share in the sale of her property.
However, the Court agrees with respondents that only questions of law are entertained in petitions for review on certiorari under Rule 45 of the Rules of Court. The trial court's findings of fact, which the Court of Appeals affirmed, are generally binding and conclusive upon this court. There are recognized exceptions to this rule, among which are: (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference is manifestly mistaken, absurd or impossible; (3) there is grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of facts are conflicting; (6) there is no citation of specific evidence on which the factual findings are based; (7) the finding of absence of facts is contradicted by the presence of evidence on record; (8) the findings of the CA are contrary to the findings of the trial court; (9) the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; (10) the findings of the CA are beyond the issues of the case; and (11) such findings are contrary to the admissions of both parties. In the instant case, petitioners failed to demonstrate that their petition falls under any one of the above exceptions. (G.R. No. 155033; December 19, 2007)
However, the Court agrees with respondents that only questions of law are entertained in petitions for review on certiorari under Rule 45 of the Rules of Court. The trial court's findings of fact, which the Court of Appeals affirmed, are generally binding and conclusive upon this court. There are recognized exceptions to this rule, among which are: (1) the conclusion is grounded on speculations, surmises or conjectures; (2) the inference is manifestly mistaken, absurd or impossible; (3) there is grave abuse of discretion; (4) the judgment is based on a misapprehension of facts; (5) the findings of facts are conflicting; (6) there is no citation of specific evidence on which the factual findings are based; (7) the finding of absence of facts is contradicted by the presence of evidence on record; (8) the findings of the CA are contrary to the findings of the trial court; (9) the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; (10) the findings of the CA are beyond the issues of the case; and (11) such findings are contrary to the admissions of both parties. In the instant case, petitioners failed to demonstrate that their petition falls under any one of the above exceptions. (G.R. No. 155033; December 19, 2007)