Uy v. Tuason
REITERATIONFacts
The Antecedents: Respondent J. M. Tuason & Co., Inc. is the registered owner of a parcel of land in Quezon City. In August 1949, petitioner Arsenio Uy occupied a portion of this land, approximately one hundred square meters, without the respondent's consent. The occupied area was identified as Exhibit B-1 on plan PCS-3824 (Exhibit B). Procedural History: On May 7, 1959, respondent filed an action for recovery of possession and damages against petitioner. The Court of First Instance of Rizal (Quezon City Branch) ruled in favor of the respondent, ordering petitioner to vacate the premises, remove his constructions, and pay monthly rentals from August 1949 until possession was restored. This decision was affirmed in toto by the Court of Appeals. The Appeal: Petitioner appealed to the Court of Appeals, raising issues of jurisdiction, the identity of the disputed land, and his status as a possessor and builder in good faith. The Court of Appeals resolved all these issues against him. Subsequently, petitioner filed a petition for certiorari with the Supreme Court, contending that the Court of Appeals erred in affirming the lower court's decision due to a misapprehension of facts and that the appellate court departed from the usual course of judicial proceedings.
Issue(s)
Whether the Court of Appeals erred in affirming the decision of the court of origin due to a misapprehension of facts. Whether the Court of Appeals, in deciding the case, departed from the accepted and usual course of judicial proceedings.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The petition for certiorari was denied for being without merit.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petitioner's contention regarding a misapprehension of facts was without merit. The Court clarified that the petition for certiorari under Rule 45 is limited to reviewing questions of law, not fact. The evidence clearly showed that the petitioner occupied only a portion of one hundred square meters, identified as Exhibit B-1 on plan PCS-3824, which was part of the respondent's land. The lower courts' findings on this matter were supported by evidence and did not constitute a misapprehension of facts that would warrant review by the Supreme Court. The Court reiterated that factual findings of the Court of Appeals are generally conclusive. On Issue 2: The Supreme Court found the second issue to be a mere corollary to the first. Since the Court had already concluded that the first issue, concerning the alleged misapprehension of facts, was without merit, there was no further need to consider whether the Court of Appeals had departed from the accepted and usual course of judicial proceedings. The affirmation of the first issue inherently meant that the proceedings were conducted in accordance with law and established procedure, thus negating any claim of departure from the usual course.
Main Doctrine
In a petition for review on certiorari under Rule 45 of the Rules of Court, the Supreme Court's review is confined to questions of law. Factual findings of the Court of Appeals are generally binding and conclusive upon the Supreme Court, unless it is shown that the appellate court gravely abused its discretion, committed a misapprehension of facts, or that its decision was based on a misstatement of facts. The registered owner of a parcel of land is entitled to recover possession thereof from any person unlawfully occupying it.