Samson v. Andal
REITERATIONFacts
The Antecedents: The case involves a loan obligation that became due on October 25, 1945. The plaintiff-appellee alleged that he offered to pay the loan in Philippine Currency based on the value of the peso on the date the loan was obtained. Procedural History: The case was initially heard by the Court of First Instance of Manila. The defendants-appellants appealed the decision directly to the Supreme Court. The Appeal: The defendants-appellants raised, among other errors, an assignment of error concerning a question of fact: whether the plaintiff offered to pay the loan in Philippine Currency based on the value of the peso on the date the loan was obtained. The appellants devoted two pages of their brief to this alleged error of fact. The appellee, in turn, argued that this factual issue was immaterial, as he was praying for declaratory relief, and contended that declaratory relief could not be granted after a breach of contract.
Issue(s)
Whether the Supreme Court has jurisdiction to decide a question of fact when the appeal is taken directly to it. Whether the issue of whether the plaintiff offered to pay the loan in Philippine Currency based on the value of the peso on the date the loan was obtained is material to the case, particularly in the context of a prayer for declaratory relief.
Ruling
The Supreme Court ordered the case remanded to the Court of Appeals for its decision, recognizing that the appeal raised a question of fact which falls within the original jurisdiction of the Court of Appeals.
Ratio Decidendi
On Issue 1: The Supreme Court held that when an appeal raises a question of fact, and it is taken directly to the Supreme Court, the case must be remanded to the Court of Appeals. The second assignment of error presented by the appellants was a question of fact, which the Court of First Instance considered material. The Supreme Court noted that two pages of the appellants' brief were dedicated to discussing this alleged error of fact. Therefore, the proper procedure is for the Court of Appeals to decide this factual issue. On Issue 2: The Court acknowledged the appellee's argument that the question of fact might be immaterial in light of the prayer for declaratory relief. However, it pointed out that Section 2, Rule 66 of the Rules of Court explicitly states that a contract or statute may be construed before there has been a breach thereof. If a breach has already occurred, the regular remedy, not declaratory relief, obtains. The Court inferred that the lower court must have considered the question material, as it was traversed by the appellant and defended by the appellee, especially since non-compliance could lead to attorney's fees amounting to twenty-five percent (25%) of the principal loan plus accrued interest.
Main Doctrine
The Supreme Court, in reviewing a case appealed directly to it, must determine if the assignments of error raise questions of fact or of law. If questions of fact are raised, as in this instance concerning the alleged error in finding a specific offer to pay a loan, the case must be remanded to the Court of Appeals, which has the original jurisdiction to decide such factual issues. Declaratory relief is only available before a breach of contract occurs; after a breach, regular remedies apply.