G.R. Nos. L-41689-90 April 8, 1987
Chua Giok Ong, petitioner, vs. Hon. Court of Appeals and People of the Philippines, respondents.

FACTS

Petitioner Chua Giok Ong was convicted of two counts of attempted estafa through falsification of commercial documents. The case stemmed from two checks, originally issued to Rattan Art and Shell Company of the Philippines, which were stolen from the mail and subsequently altered. The payee names and amounts were falsified. Ng Bun Seng, an acquaintance of Chua, brought these altered checks to Chua and asked him to deposit them into his current account with China Banking Corporation. Chua examined the checks, observed the obvious alterations, and inquired about their origin. Upon being told they came from a friend, Chua endorsed the checks and prepared a deposit slip. Ng deposited them the following day. The checks were later dishonored due to the alterations. Days later, at Ng’s request, Chua issued two personal checks corresponding to the amounts of the altered checks, which Ng attempted to encash, leading to his arrest.

ISSUE

Whether the Supreme Court can review the factual findings of the Court of Appeals regarding Chua Giok Ong’s knowledge of the falsification and his participation in a conspiracy to defraud.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals’ decision. The Court held that the appeal raised purely factual questions, which are not reviewable in a petition for review on certiorari under Rule 45 of the Rules of Court. The Court emphasized that its appellate jurisdiction in such petitions is limited to questions of law, not fact, unless the case falls under specific exceptions, which were not present here. The factual conclusions of the Court of Appeals—that Chua’s actions, including endorsing obviously altered checks, providing an incorrect address to the bank, and subsequently issuing personal checks for the equivalent amounts, demonstrated his complicity in the conspiracy to defraud—are binding and conclusive. The Supreme Court found no capriciousness or whimsicality in these findings and no error of law in the appellate court’s decision. Consequently, the conviction and the penalties, as modified by the Court of Appeals, were upheld. The ruling reinforces the doctrine of finality of factual determinations by lower courts and the limited scope of certiorari as a mode of appeal to the Supreme Court.