Central Bank v. Castro
REITERATIONFacts
The Antecedents: The Central Bank of the Philippines (Petitioner) sought to recover ₱100,000.00 allegedly over-transferred to Aurora P. Castro (Respondent), former Chief of the Tellers Division. The over-transfer allegedly occurred during a routine cash transfer procedure. Procedural History: The trial court dismissed the case for lack of evidence. The Court of Appeals affirmed the dismissal. Petitioner filed a Petition for Review on Certiorari. The Petition: Petitioner contends that the trial court and appellate court misapprehended facts and erred in dismissing the case. Petitioner argues that respondent, as an accountable officer, is liable for the over-transferred amount, invoking Presidential Decree No. 1445.
Issue(s)
Whether the Supreme Court can review factual findings of the lower courts in a petition for review on certiorari under Rule 45. Whether respondent Aurora P. Castro is liable for the alleged over-transfer of ₱100,000.00.
Ruling
The petition is denied for failing to raise a genuine question of law. The Decision and Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the issue of whether the Supreme Court can review factual findings: The Court reiterated that a petition for review on certiorari under Rule 45 of the Rules of Court is confined to questions of law. A question of law arises when there is doubt or controversy as to what the law is on a certain state of facts, whereas a question of fact arises when the doubt or difference pertains to the truth or falsehood of facts or requires a calibration of the entire evidence. The Court emphasized that the test is whether the appellate court can determine the issue without reviewing or evaluating the evidence. In this case, the petitioner's arguments necessitated a review and evaluation of the evidence presented, making it a question of fact, which is not proper in a Rule 45 petition. The Court also noted that none of the exceptional circumstances that would warrant a review of factual findings were present. On the issue of respondent's liability for the alleged over-transfer: The Court held that the petitioner failed to prove the alleged over-transfer of ₱100,000.00 by a preponderance of evidence. The petitioner's theory that respondent is deemed to have received the bundle through her subordinate, Flores, would only be relevant if the over-transfer itself was proven. The Court pointed out the negligence of the accountable officer, de Vera, in failing to record the extra bundle in her control sheet and in the Cash Transfer Slip, and in giving the bundle to Dagot without further instruction. The testimony of de Vera was not categorically corroborated by evidence that would prove the subject bundle was not part of the recorded bundles. Consequently, since the fact of over-transfer was not proven, the obligation to return the subject amount did not arise, and the lower courts correctly dismissed the case.
Main Doctrine
A petition for review on certiorari under Rule 45 of the Rules of Court is limited to questions of law and does not allow a review of factual issues, such as the credibility of witnesses and the probative value of evidence, unless exceptional circumstances exist. The failure to prove the over-transfer of funds by a preponderance of evidence warrants the dismissal of the case.