Santos v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership and validity of two deeds of sale executed by Asuncion Santos in favor of Gavino Ramos. The first deed, dated August 28, 1961, covered Lot 1317, and the second, dated September 24, 1964, covered Lot 559-B. The Intermediate Appellate Court (IAC) found that the second sale was merely a substitution for the first, as the title to Lot 1317 could not be registered due to its loss. Evidence presented included a prior agreement (Kasunduan) for the construction and use of a fishpond on Lot 1317, a subsequent written lease agreement between Santos and Francisco Castro (Ramos' son-in-law) for Lot 1317, a criminal case for falsification related to lease rentals of Lot 1317 where Ramos was found to be the owner, and the fact that Ramos took possession of Lot 559-B but not Lot 1317, while Castro paid taxes on Lot 1317. 2. Procedural History: Gavino Ramos initiated the case by filing a petition for declaratory relief in the trial court, naming Asuncion Santos as the respondent. The trial court rendered a judgment in favor of Ramos. Asuncion Santos appealed this decision to the Intermediate Appellate Court (IAC). The IAC affirmed the trial court's decision, finding no merit in Santos' appeal. Santos then filed a motion for reconsideration with the IAC, which was denied. This led to the present petition for review by way of certiorari to the Supreme Court. 3. The Petition: Asuncion Santos, as petitioner, filed a petition for review by way of certiorari, challenging the IAC's decision. The petition raised three main issues: (I) that the lower court erred in granting a petition for declaratory judgment when the proper action should have been for reconveyance or nullity of document; (II) that the lower court erred in ordering the quieting of Ramos' title over Lot 1317; and (III) that the lower court erred in annulling the deed of sale for Lot 1317 within a petition for declaratory judgment. The Supreme Court found these contentions to be without merit, noting that the procedural issue was not raised in the trial court and that the other issues involved factual determinations already settled by the lower courts.
Issue(s)
Whether the propriety of a Petition for Declaratory Relief can be challenged for the first time on appeal when the petitioner abandoned said issue during the trial. Whether the factual findings of the lower court—concluding that the second sale was a substitution for the first—are binding on the Supreme Court.
Ruling
The Supreme Court affirmed the decision of the Intermediate Appellate Court, dismissing the petition for review. The Court held that the issue regarding the propriety of the action for declaratory relief was deemed abandoned as it was not raised in the trial court. The Court also found no reversible error in the appellate court's factual findings, which were supported by substantial evidence.
Ratio Decidendi
On Issue 1: The Supreme Court held that the petitioner could not challenge the propriety of the Petition for Declaratory Relief because she failed to pursue this argument in the trial court. While her answer and early manifestations hinted at questioning the procedural vehicle, she later manifested a desire to continue with the hearing until terminated, effectively abandoning the point. Under Philippine jurisprudence, issues, theories, and arguments not adequately brought to the attention of the trial court will not be considered by a reviewing court. This rule prevents a party from surprising an opponent with a new theory on appeal that was not ventilated during the trial. Because the lower courts did not even touch upon the issue, it would be improper for the Supreme Court to consider it now. On Issue 2: The Supreme Court ruled that the findings regarding the substitution of the sale were essentially factual and supported by sufficient evidence. The Court emphasized that it is not its function to re-examine the evidence unless there is a clear and manifest error, which was not present in this case. Documentary evidence, such as the lease contract between the petitioner's son-in-law and the respondent, proved that the petitioner's family recognized the respondent's ownership of Lot 1317. Furthermore, the lack of possession and non-payment of taxes by the petitioner over Lot 1317, contrasted with her possession of the substituted Lot 559-B, strongly indicated the parties' true intent. The Court deferred to the trial judge's assessment of witness credibility, noting that such findings are generally not disturbed on appeal.
Main Doctrine
The Supreme Court reiterated the general principle that points of law, theories, issues of fact, and arguments not adequately brought to the attention of the trial court need not be, and ordinarily will not be, considered by a reviewing court, as they cannot be raised for the first time on appeal. Furthermore, the Court emphasized that factual findings of the appellate court, which are supported by substantial evidence, are generally binding and will not be disturbed on appeal, particularly concerning the credibility of witnesses and the appreciation of evidence.