GR 106472; (August, 1996) (Digest)
G.R. No. 106472 August 7, 1996
JUAN CASTILLO and MARIA MASANGYA-CASTILLO (substituted by their legal heirs), petitioners, vs. COURT OF APPEALS, REGIONAL TRIAL COURT OF AKLAN, and ROSITA MASANGYA, respondents.
FACTS
Private respondent Rosita Masangya filed a complaint for quieting of title over a parcel of land in Aklan. She claimed ownership through a chain of title originating from her father, Luis Masangya, the primitive owner. The land was sold at a public auction for tax delinquency in 1937 to Presentacion Relado, who later sold it to Rosita. This sale was confirmed by Relado’s heirs. Rosita and her brother Isidro possessed the land, and she subsequently declared it for taxation in her name and paid the corresponding taxes.
The petitioners, the heirs of the Castillo spouses, opposed the claim. The Regional Trial Court ruled in favor of Rosita Masangya, finding that she had sufficiently established her ownership through preponderant evidence, including tax declarations, certificates of sale, and confirmation documents. The Court of Appeals affirmed the trial court’s decision in toto.
ISSUE
Whether the Supreme Court can review and overturn the factual findings of the Court of Appeals which affirmed the trial court’s findings.
RULING
The Supreme Court dismissed the petition and affirmed the assailed decisions. The Court reiterated the fundamental principle that factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and conclusive upon the Supreme Court. The Court’s jurisdiction in a petition for review under Rule 45 is limited to reviewing errors of law, not re-examining factual determinations.
The legal logic is anchored on the respect for the expertise of lower courts in assessing the credibility of witnesses and the weight of evidence. The Supreme Court will not disturb these findings absent any clear showing of grave abuse of discretion, or that the conclusions were grounded entirely on speculation, surmises, or conjectures; or that the inferences made were manifestly absurd. The petitioners failed to demonstrate that the case fell under any of the recognized exceptions to the rule. The Court found that the findings of both lower courts were amply supported by the evidence on record, including documentary evidence tracing Rosita Masangya’s title. Thus, there was no reversible error to justify a departure from the conclusive factual findings.