Bernardo v. Court of Appeals
REITERATIONFacts
The Antecedents: Plaintiffs (respondents herein) filed an amended complaint for partition and annulment of conveyance of three parcels of land in Rizal, alleging they were community properties of the deceased spouses Miguel Bernardo and Lorenzo Garcia. The plaintiffs claimed shares as grandchildren of Miguel Bernardo and Lorenzo Garcia, whose six children were Ceferino, Bonifacio, Narciso, Justo, Gregoria (alias Yoyang), and Petronila. Procedural History: The Court of First Instance of Rizal dismissed the complaint. The plaintiffs appealed to the Court of Appeals, which initially affirmed the trial court's decision. However, upon motion for reconsideration, a division of the Court of Appeals reversed its original decision, declaring the lands as community properties and ordering partition in specific proportions (3/5 to heirs of Ceferino, Bonifacio, and Narciso; 2/5 to heirs of Gregoria and Justo). The Petition: Petitioners (defendants-appellees in the CA) filed a petition for certiorari with the Supreme Court, questioning the Court of Appeals' resolution that reversed its own decision. They argued that the appellate court could not validly declare the properties as community properties after finding that the shares of respondents' predecessors were ceded to their father, Justo Bernardo, over 70 years prior. They also questioned the validity of demanding partition after such a long period of exclusive possession by their father and themselves, and whether the appellate court could decide contrary to its own findings of fact based on unfounded assumptions.
Issue(s)
Whether the Court of Appeals may validly declare properties as community properties after its own finding that shares were ceded to petitioner's father over 70 years ago. Whether private respondents may still demand partition after more than 70 years of exclusive possession by petitioners' father and petitioners. Whether private respondents may validly claim shares after petitioners' father claimed the properties exclusively for himself with the alleged knowledge and consent of respondents' predecessors. Whether the Court of Appeals may decide a case contrary to its own findings of fact and on the basis of unfounded assumptions. Whether a decision unanimously promulgated by a division of three Justices can be reconsidered and set aside by a resolution promulgated later, excluding two of the original Justices, without a hearing.
Ruling
The petition for certiorari is denied. The resolution of the Court of Appeals promulgated on August 31, 1968, is affirmed.
Ratio Decidendi
On Issue 1: The Court held that the Court of Appeals did not err in reconsidering its decision and declaring the properties as community properties. The Court of Appeals' resolution was based on a careful review of the evidence, which showed that the lands were originally owned by Miguel Bernardo. The quitclaim (Exhibit 30) executed by Ceferino, Bonifacio, and Gregoria in favor of Justo Bernardo, conditioned on Justo assuming their father's debts, indicated that Justo acknowledged their co-ownership derived from Miguel Bernardo. The Court found that the defendants' assertion of exclusive ownership by Justo Bernardo was not satisfactorily explained, while the plaintiffs' evidence traced the origin of the properties to Miguel Bernardo. On Issue 2: The Court implicitly addressed this by affirming the partition. The reversal of the original decision by the Court of Appeals, which declared the properties as community properties, meant that the claim for partition was deemed valid. The Court found that the quitclaim executed by some siblings in favor of Justo Bernardo did not extinguish the co-ownership rights of other siblings (Narciso and Petronila) who did not participate in the quitclaim. Therefore, the demand for partition was legally permissible. On Issue 3: The Court found that the evidence supported the conclusion that the lands were community properties. The quitclaim (Exhibit 30) itself indicated that Justo Bernardo acknowledged the co-ownership rights of his siblings, Ceferino, Bonifacio, and Gregoria, derived from their father, Miguel Bernardo. The assertion that Justo claimed the properties exclusively for himself with the knowledge and consent of others was not sufficiently substantiated to overcome the evidence of original co-ownership and the terms of the quitclaim. On Issue 4: The Court rejected the argument that the Court of Appeals decided contrary to its own findings of fact. The Court stated that the resolution appealed from was based on a careful review of the evidence, leading to the conclusion that the lands were community properties. The Court reiterated that findings of fact by the Court of Appeals are generally final and conclusive and are not subject to review by the Supreme Court unless there are exceptional circumstances, which were not present here. On Issue 5: The Court affirmed the inherent power of the Court of Appeals to amend and control its process and orders so as to make them conformable to law and justice, citing Paragraph (g), Section 5, Rule 135 of the Revised Rules of Court. The Court found that the Court of Appeals did not just set aside its original decision without reviewing the evidence. The reversal was a result of a motion for reconsideration where the appellate court carefully reviewed the evidence of record, leading to a different conclusion.
Main Doctrine
The Supreme Court reiterated that findings of fact by the Court of Appeals are generally final and conclusive and cannot be reviewed in a petition for certiorari, provided they are supported by substantial evidence. The Court emphasized that its power of review is limited to errors of law and not of fact, unless specific exceptions apply, such as a showing that the appellate court's findings are not supported by substantial evidence or that it committed a grave abuse of discretion.