G.R. No. 97838 May 12, 1993
LA CAMPANA FOOD PRODUCTS, INC., petitioner, vs. THE COURT OF APPEALS, TIMOTHY M. ANG and BETHLEHEM MANUFACTURING, INC., respondents.

FACTS

Petitioner La Campana Food Products, Inc. is the owner-lessor of a warehouse-type building in Quezon City, partitioned and leased to several lessees, including private respondent Bethlehem Manufacturing, Inc. (represented by its majority stockholder Timothy M. Ang). On August 1, 1983, a fire broke out, heavily damaging the building and the properties of Bethlehem Manufacturing inside. Petitioner filed a complaint for damages against Bethlehem Manufacturing, alleging the fire’s proximate cause was the negligence of the lessee’s employees in storing flammable materials in violation of the lease agreement and failing to install proper safeguards. Petitioner sought actual damages and attorney’s fees. Private respondents countered that the fire started elsewhere, denied negligence, and filed counterclaims for actual, moral, and exemplary damages and attorney’s fees. The Regional Trial Court dismissed petitioner’s complaint and ordered it to pay damages to private respondents. The Court of Appeals modified the decision by deleting the award of actual damages but increasing the moral damages. Petitioner filed this petition for review, raising issues on the admissibility of evidence, the nature of the action, reliance on investigation reports, witness credibility, the significance of high fire insurance coverage, and the basis for the damages awarded.

ISSUE

The core issue is whether the Court of Appeals committed reversible errors in its factual findings and legal conclusions that led to the dismissal of petitioner’s complaint and the award of damages to private respondents.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the issues raised by petitioner involved factual matters, and in a petition for review on certiorari under Rule 45, only questions of law may be raised. The findings of fact of the Court of Appeals are conclusive and binding, absent any showing that the case falls under the recognized exceptions. The Court found no reversible error in the respondent court’s decision.
Specifically:
1. On the admissibility of exhibits (xerox copies), the respondent court correctly held that the exhibits were sufficiently identified and testified to by witnesses during trial, making them admissible.
2. The cause of action was properly treated as based on tort (quasi-delict), as the allegations in the complaint centered on the negligence of the lessee’s employees, which is a tortious act.
3. The respondent court did not err in relying on the police and insurance adjuster’s reports, as these were properly presented and testified to by competent witnesses.
4. The assessment of witness credibility by the trial court, affirmed by the Court of Appeals, is entitled to great respect.
5. The high fire insurance coverage was not indicative of wrongdoing, as the value of the insured properties was substantiated by evidence.
6. The award of moral damages was justified due to the wrongful attachment of private respondents’ properties by petitioner, which caused besmirched reputation, wounded feelings, and social humiliation. The reduction of actual damages by the Court of Appeals was also proper due to insufficient evidence.
The Supreme Court emphasized that the jurisdiction of the Supreme Court in cases from the Court of Appeals is limited to reviewing errors of law, and the findings of fact of the Court of Appeals are conclusive. Petitioner’s case did not fall under any exception to this rule.