Valdez v. Reyes
REITERATIONFacts
The Antecedents: The parties are heirs of Doroteo Bonalos, who owned fourteen parcels of land. Doroteo died intestate in 1937. Petitioners are children and grandchildren of Doroteo, while respondents are grandchildren of Doroteo by his first wife. Procedural History: Petitioners filed a complaint for Partition with Damages against respondents, alleging co-ownership pro-indiviso and that respondents were in possession of the properties and appropriating their produce. Respondents denied the allegations, claiming the properties were already partitioned among the heirs during Doroteo's lifetime and that petitioners had sold their shares. The RTC dismissed the complaint, finding no remaining properties for partition and that petitioners' shares were sold or transferred. The RTC also ordered petitioners to pay damages and attorney's fees. The Court of Appeals affirmed the RTC judgment but deleted the award of moral damages. The Petition: Petitioners seek review of the Court of Appeals' decision, arguing that the findings of fact should be re-examined.
Issue(s)
Whether the Supreme Court can re-examine the findings of fact of the Court of Appeals and the Regional Trial Court. Whether the petitioners are entitled to partition and damages.
Ruling
The petition is DENIED and the assailed Decision dated January 30, 2002 of the Court of Appeals in CA-G.R. CV No. 57088 is AFFIRMED, with modification in the sense that the award of moral damages to respondents is deleted.
Ratio Decidendi
On the issue of re-examining findings of fact: The Supreme Court reiterated the jurisprudential doctrine that the findings of the Court of Appeals, especially when they coincide with those of the trial court, are binding on the Supreme Court. The Court emphasized that it is not a trier of facts and its function is not to re-examine and weigh anew the evidence presented by the parties. This doctrine remains undisturbed unless the factual findings are demonstrably unsupported by the evidence on record. The petitioners failed to provide any compelling reason why this established doctrine should not apply to their case. Therefore, the Court will not disturb the factual conclusions reached by the lower courts regarding the ownership and disposition of the properties in question. The Court's role is limited to reviewing errors of law, not of fact. On the entitlement to partition and damages: Based on the affirmed findings of fact by the RTC and the Court of Appeals, it was established that no property remained in the estate of Doroteo Bonalos that could be the subject of partition. The lower courts found that the petitioners' shares, if any, were already sold or transferred to the respondents and other persons. Consequently, the claim for partition was dismissed. Furthermore, the Court of Appeals modified the RTC's award of moral damages by deleting it, indicating that the grounds for such damages were not sufficiently established or were not warranted under the circumstances. The award of attorney's fees was also deleted by the appellate court, implying a lack of basis for such claim as well.
Main Doctrine
The findings of the RTC, as affirmed by the appellate court, are binding on the Supreme Court, which is not a trier of facts and cannot re-examine and weigh anew the respective evidence of the parties, unless such findings are not supported by the evidence on record.