Peña v. Lim
REITERATIONFacts
The Antecedents: Plaintiff Mary de la Peña, on behalf of her minor daughter Teresita Lim, filed an action against defendant Peng Huan Lim for acknowledgment and support. The complaint alleged that plaintiff and defendant lived together as husband and wife from January 1946 to October 1947, during which Teresita Lim was born on June 24, 1947. It was claimed that both parties were single at the time of conception, the defendant paid for the midwife, and Teresita was treated as the defendant's natural child and supported by him until their separation in October 1947. The plaintiff sought support in arrears of P6,150.00 and monthly support of P50.00, plus attorney's fees. Procedural History: The defendant filed an answer with specific denials, affirmative defenses (lack of legal capacity of plaintiff, failure to state a cause of action), and a counterclaim for damages. After trial, the Court of First Instance dismissed both the complaint and the counterclaim, finding that the plaintiff failed to present sufficient evidence. The plaintiff appealed this decision. The Petition: The plaintiff appealed, raising two main issues: (1) whether she had the legal capacity to initiate the action, and (2) whether the trial court erred in finding insufficient evidence to substantiate her complaint and in discrediting her testimony while believing the defendant's.
Issue(s)
Whether the Supreme Court has jurisdiction to review an appeal that involves both questions of law and questions of fact under the Judiciary Act of 1948.
Ruling
The Supreme Court directed the Clerk of Court to certify the case to the Court of Appeals for proper action.
Ratio Decidendi
On Issue 1: The Supreme Court reasoned that the review of the trial court's judgment falls under the exclusive jurisdiction of the Court of Appeals because the appeal involves both issues of law and issues of fact. While the appellant raised a legal question regarding capacity to sue, the core of the grievance was the trial court's evaluation of the evidence concerning the status of the child. Applying Section 17, paragraph 3 [5] of the Judiciary Act, the Court noted that jurisdiction is determined by the nature of the questions raised in the appeal. Citing the precedents in Estrada vs. Noble (G.R. No. L-2726, 1950) and Manuel C. Ramos vs. People's Surety and Insurance Co., Inc. (G.R. No. L-7607, 1960), the Court emphasized that cases requiring the calibration of evidence belong in the Court of Appeals. The Court found that since it would need to determine the credibility of the witnesses and the weight of the evidence to resolve the appeal, it must relinquish the case. Consequently, as the case was not within the Supreme Court's exclusive jurisdiction, it ordered the certification of the records to the Court of Appeals.
Main Doctrine
The Supreme Court certified the case to the Court of Appeals as it involved both issues of law and fact, falling under the exclusive jurisdiction of the latter.