Goduco v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Herminia Goduco sought a commission for the sale of a land. The case involved the estate of the late Maria B. Castro. Procedural History: This Court rendered judgment on February 28, 1964, affirming the findings of the Court of First Instance of Manila and the Court of Appeals. A Motion for Reconsideration and/or New Trial filed by the appellant was denied on March 30, 1964. Subsequently, a Second Motion for Reconsideration and/or New Trial was filed by the appellant herself, along with other pleadings. Respondents were required to answer this second motion due to the nature of its allegations. The Petition: The appellant, Herminia Goduco, filed a Second Motion for Reconsideration and/or New Trial, predicated on allegedly newly discovered evidence. This evidence consisted of a receipt purportedly thumb-marked by Mauricia Dionisio, the owner of the lot, indicating full payment of P50,000.00 by the late Maria B. Castro for the land. The appellant also sought to have her claim recognized in the intestate proceedings of Maria B. Castro.
Issue(s)
Whether the Supreme Court can entertain a motion for a new trial based on newly discovered evidence in an appeal by certiorari involving questions of fact. Whether the issues raised in the motion for reconsideration and/or new trial are rendered moot or academic by other pending proceedings.
Ruling
The Second Motion for Reconsideration and/or New Trial, along with the prayer of counsel for the Administratrix of the Intestate Estate of Maria B. Castro, is DENIED. The judgment of the Court of Appeals is affirmed.
Ratio Decidendi
On Issue 1: The Supreme Court denied the motion for reconsideration and/or new trial, emphasizing that it is not authorized to entertain such motions based on allegedly newly discovered evidence when the case involves only questions of fact. The Court cited Moran on the Rules of Court, stating that in an appeal by certiorari, the Supreme Court has no jurisdiction to entertain a motion for a new trial on the ground of newly discovered evidence, as the findings of fact by the Court of Appeals are conclusive. The Court reiterated that its previous decision affirmed the findings of fact and conclusions of both the Court of First Instance and the Court of Appeals. On Issue 2: The Court noted that the petitioner, Herminia Goduco, had already presented a motion in the intestate proceedings of Maria B. Castro (Sp. Proc. No. 52975) for the recognition of her money claim against the estate, which was admitted by the probate court. Furthermore, a reconveyance case had been presented by the estate against Sostenes Campillo. These developments, as asserted by Atty. Tansinsin and not denied by the administratrix's counsel, render the issues raised in the motion for reconsideration and/or new trial moot or academic.
Main Doctrine
The Supreme Court, in an appeal by certiorari under Rule 45 of the Rules of Court, is confined to reviewing errors of law and cannot entertain a motion for a new trial based on newly discovered evidence if the case involves only questions of fact. The factual findings of the Court of Appeals are considered conclusive and binding on the Supreme Court.