GR 929; (September, 1902) (Digest)
G.R. No. 929 : September 5, 1902
THUNGA CHUI, plaintiff-appellee, vs. QUE BENTEC, defendant-appellant.
FACTS:
This is an appeal from a judgment in an ordinary civil action. The defendant-appellant, Que Bentec, excepted only to the final judgment rendered by the trial court. The bill of exceptions filed contained only the complaint, answer, and judgment, and it was stated that the defendant took no other exceptions during the proceedings. The appellant moved before the Supreme Court to amend the bill of exceptions by adding all the evidence taken at the trial.
ISSUE:
Whether the Supreme Court should grant the appellant’s motion to amend the bill of exceptions to include all the evidence from the trial.
RULING:
The Supreme Court DENIED the motion. The Court explained the scope of its appellate jurisdiction. In ordinary civil actions, under the Code of Civil Procedure (specifically Article 497), the Supreme Court’s power is limited to correcting errors of law; it is generally prohibited from reviewing evidence or retrying questions of fact, except in three specific cases not applicable here. Since the defendant only excepted to the judgment, his appeal is limited to arguing that, based on the facts as found and stated by the trial judge, the judgment was erroneous as a matter of law. He cannot challenge the factual findings themselves. Furthermore, because the bill of exceptions shows no exceptions were taken to any evidentiary rulings during trial, there are no alleged errors of law concerning the admission or exclusion of evidence for the Court to review. Even if all the evidence were transmitted, the Court would have no authority to examine it for factual review or for unpreserved legal errors. The appellant was given thirty days to file his brief.
