G.R. No. 171722 – 776 Phil. 167 – 778 SCRA 189 – Political Law – Constitutional Law – The Judicial Department – The Supreme Court – Powers of the Supreme Court – The Supreme Court is not a Trier of Facts; Exception
Burgos won a judgment award against Pascual. Pascual was unable to pay hence their property was levied and was sold in a public auction in 1982. Burgos was the highest bidder at Php95k for the ten-hectare property (fishpond in Bulacan).
Pascual questioned the auction sale as they claimed that the auction price was unconscionably low. Eventually, the trial court conducted hearings to determine the fair market value. Pascual presented witnesses and documents which proved that the fair market value of fishponds in Bulacan in 1982 were worth Php200k per hectare. Burgos presented countervailing evidence. After trial, the trial court rendered a decision in favor of Pascual and ruled that the auction price should be at Php2M.
On appeal, the Court of Appeals reversed the findings of the trial court. It ruled that the witnesses and documents presented by Pascual should not have been given weight due to inconsistencies. Pascual moved for reconsideration but was denied. They filed a petition for review on certiorari with the Supreme Court.
ISSUE: Whether or not it is proper for the Supreme Court to review the findings of facts of the Court of Appeals in this case.
HELD: No. As a rule, the Supreme Court is bound by the findings of facts of the Court of Appeals. One of the exceptions of this rule is if there are contrary findings between the trial court and that of the CA. However, not every disagreement between the trial court and the CA would warrant a review by the SC of the facts. The CA and the trial court may rule differently as to the weight of evidence presented but the findings of facts by the CA will bind the SC so long as its findings are borne out by the record or based on substantial evidence.
In this case, the CA’s ruling on the inconsistencies of the evidence presented by Pascual was supported by the record. Pascual claimed that the FMV is at Php200k per hectare. To support their claim, they presented a deed of sale which purportedly showed that the selling price of a 40 hectare property was Php10M. However, a scrutiny by the CA of the deed of sale presented revealed that the selling price truly indicated there was Php4M and Pascual was unable to explain the discrepancy.
