Ungson v. Basco
REITERATIONFacts
The Antecedents: Plaintiff Simon Ungson filed an action in the Court of First Instance of La Union to recover possession of a parcel of land approximately 5 hectares in size. The defendant filed a general denial. Procedural History: The trial court rendered a decision stating that the preponderance of proof did not support the plaintiff's claim but failed to state any facts upon which this conclusion was based. The plaintiff appealed to the Supreme Court. The Petition: The plaintiff's first assignment of error was the lower court's failure to make a statement of facts supporting its conclusion, citing Section 133 of the Code of Procedure in Civil Actions and numerous Supreme Court decisions.
Issue(s)
Whether the lower court committed an error in not making a statement of facts upon which its conclusions were based. Whether the failure to make a finding of facts constitutes a reversible error.
Ruling
The Supreme Court ordered that the record be remanded to the lower court with the direction that the judge thereof make a finding of facts based upon the proof already presented and return such finding to the Supreme Court within thirty days. The Court made no finding as to costs.
Ratio Decidendi
On the issue of the lower court's failure to make a statement of facts: The Supreme Court held that judges of the Court of First Instance are required by Section 133 of the Code of Procedure in Civil Actions to make a finding of facts upon which they base their conclusions. This requirement has been consistently upheld in numerous prior decisions of the Court. The failure to do so deprives the parties of the right to know the factual basis of the judgment and hinders the appellate court's review. Therefore, such failure constitutes a reversible error. On the issue of whether the failure to make a finding of facts constitutes a reversible error: The Court reiterated its established doctrine that a failure to make a finding of facts upon which conclusions are based is a reversible error. Consequently, the proper remedy is to remand the case to the lower court with specific instructions for the judge to make the required finding of facts based on the existing evidence. This ensures that the appellate court can properly review the case and that the parties are informed of the factual underpinnings of the decision.
Main Doctrine
A failure by the lower court to make a finding of facts upon which its conclusions are based, in accordance with Section 133 of Act No. 190, constitutes a reversible error, warranting the remand of the case to the lower court with directions to make such finding.