GR 111324; (July, 1996) (Digest)
G.R. No. 111324 July 5, 1996
ROMAN CATHOLIC ARCHBISHOP OF MANILA, petitioner, vs. COURT OF APPEALS, SPS. ERNESTO REYES and LORNA REYES, respondents.
FACTS
The Roman Catholic Archbishop of Manila (petitioner) leased a parcel of land to spouses Ernesto and Lorna Reyes (respondents). The respondents discovered an encroachment of 30.96 square meters by an adjacent property. They demanded the petitioner to correct this but received no action, leading them to withhold rental payments as leverage. Separately, the petitioner offered to sell the property. The respondents expressed interest but the parties failed to agree on a price, as the respondents insisted on the 1987 price while the petitioner offered a higher 1989 price.
The respondents filed a complaint for specific performance and damages before the Regional Trial Court (RTC). Their first cause of action sought correction of the encroachment. Their second cause of action sought to compel the petitioner to sell the property at the 1987 price. The RTC dismissed the second cause of action, finding no perfected contract of sale, but allowed the first cause to proceed. Subsequently, the RTC rendered a partial judgment on the pleadings, ordering the respondents to pay rental arrears for the undisputed area of the lease. The respondents appealed this partial judgment to the Court of Appeals (CA).
ISSUE
The primary issue is whether the Court of Appeals had jurisdiction over the appeal from the RTC’s partial judgment, which the petitioner argued raised only questions of law.
RULING
The Supreme Court ruled that the Court of Appeals correctly assumed jurisdiction. The appeal did not involve purely questions of law. A question of law exists when the doubt concerns the correct application of law or jurisprudence to a certain set of facts. A question of fact exists when the doubt pertains to the truth or falsity of alleged facts. Here, the respondents’ appeal from the partial judgment on rental payments necessitated a review of factual matters. These included determining whether there was a valid cause to suspend rental payments due to the alleged encroachment, the exact area affected, and the corresponding adjustment in rental obligations. These are quintessential questions of fact requiring the evaluation of evidence. Consequently, the appeal was not limited to questions of law, and the Court of Appeals, under its jurisdiction to review questions of fact and law, properly took cognizance of the case. The petition was denied.