Toriano v. Trieste
REITERATIONFacts
The Antecedents: Petitioner Godofredo Toriano sold a 669.32 square meter parcel of land to respondent Generoso Trieste, Sr. on September 13, 1975. Three days later, Trieste purchased an adjoining 664-square meter lot from petitioner's sister, Salvacion Toriano. Trieste later secured a tax declaration for both lots and mortgaged them to Development Bank of the Philippines (DBP) to secure a loan. Upon failure to pay, DBP foreclosed the mortgage, and the lots were sold at public auction to respondent Reuben Ibarreta as the highest bidder. Procedural History: On February 16, 1988, petitioner filed a complaint for forcible entry against Trieste, alleging that Trieste forcibly entered a 242-square meter lot outside the original sale. The Municipal Circuit Trial Court dismissed the complaint upon petitioner's manifestation to file a suit for recovery of possession and ownership. Subsequently, on September 19, 1990, petitioner filed a Complaint for Recovery of Possession and Ownership and for Declaration of Nullity of Contracts against Trieste, DBP, and Ibarreta. The Regional Trial Court (RTC) dismissed the complaint on July 25, 1995, holding that the disputed 242-square meter lot was included in the 669.32-square meter lot sold by petitioner to Trieste. The Court of Appeals affirmed the RTC's decision, and a subsequent motion for reconsideration was denied. The Petition: Petitioner filed a Petition for Review on Certiorari assailing the Court of Appeals' decision, contending that the appellate court erred in affirming the trial court's finding that the 242-square meter portion was included in the lot he sold to Trieste.
Issue(s)
Whether the Court of Appeals erred in affirming the finding of the trial court that the 242-square meter portion under controversy is included in the 669.32-square meter lot sold by petitioner to Trieste. Whether the Supreme Court can re-examine factual findings of the lower courts in a petition for review on certiorari.
Ruling
The petition must fail. The Supreme Court denied the petition and affirmed the challenged Decision and Resolution of the Court of Appeals. Costs were against the petitioner.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the finding of the trial court that the 242-square meter portion under controversy is included in the 669.32-square meter lot sold by petitioner to Trieste: This issue pertains to a question of fact, specifically the determination of the boundaries and inclusion of a disputed area within a previously sold lot. The Supreme Court reiterated its long-standing policy that it is not a trier of facts. The Court's role in a petition for review on certiorari under Rule 45 is to pass upon questions of law, not to re-evaluate evidence or factual findings made by the lower courts. The findings of the RTC, as affirmed by the Court of Appeals, are generally conclusive and binding upon the Supreme Court, absent any showing that the case falls under any of the recognized exceptions to this rule. On the issue of whether the Supreme Court can re-examine factual findings of the lower courts in a petition for review on certiorari: The Supreme Court definitively stated that it is not its function to examine and evaluate the probative value of the evidence presented before the lower tribunals. In a petition for review on certiorari under Rule 45 of the 1997 Rules of Procedure, as amended, only questions of law may be raised. The petitioner's contention that the 242-square meter portion was not included in the sale is a factual claim that requires a review of evidence, which is beyond the scope of a Rule 45 petition. The petitioner failed to demonstrate that his case falls under any of the established exceptions to the rule on the conclusiveness of factual findings of lower courts, such as when the findings are not supported by evidence, or when the judgment is based on a misapprehension of facts.
Main Doctrine
A petition for review on certiorari under Rule 45 of the Rules of Court is limited to questions of law, and the Supreme Court is not a trier of facts. Factual findings of lower courts are generally conclusive, unless the case falls under established exceptions, which were not present in this instance.