GR 130826; (February, 2004) (Digest)
G.R. No. 130826 ; February 17, 2004
EMMANUEL SAMALA, VIOLETA SAMALA and HEIRS OF EMILIANO SAMALA, petitioners vs. COURT OF APPEALS, REGIONAL TRIAL COURT, BRANCH 154, PASIG CITY, METRO MANILA and PILHINO SALES CORP., respondents.
FACTS
Pilhino Sales Corporation sold two Hino trucks on installment to petitioners Emmanuel, Violeta, and Emiliano Samala. To secure the balance, the Samalas executed two promissory notes and two chattel mortgage contracts. Pilhino alleged the collateral consisted of seven truck units. Upon the Samalas’ default, Pilhino filed an action for replevin. The trial court issued a writ of seizure, resulting in the taking of three of the Samalas’ trucks.
The Samalas countered that only the two newly purchased trucks were mortgaged, not seven. They asserted one seized truck had been previously released from a separate mortgage and was wrongfully taken. They prayed for the trucks’ return and damages for lost income. The trial court ruled for Pilhino, confirming its possession of the three seized trucks as sufficient to cover the debt and dismissing the counterclaim. The Court of Appeals affirmed this decision.
ISSUE
The core legal issue is whether the Supreme Court can review the factual determinations made by the lower courts regarding the number of trucks validly mortgaged and the legality of the seizure, within a petition for review on certiorari under Rule 45.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The petition essentially raised factual questions, such as the exact number of trucks mortgaged and the justification for the seizure of a specific truck. Under Rule 45 of the Rules of Court, the Supreme Court’s jurisdiction is limited to reviewing questions of law, not re-examining factual findings. The factual conclusions of the trial court, especially when affirmed by the Court of Appeals, are binding and conclusive unless they fall under established exceptions.
The Court found petitioners failed to demonstrate that their case fell under any recognized exception to this rule. Both lower courts uniformly found, based on the evidence, that the chattel mortgage contracts indeed covered seven trucks, including the disputed unit which, despite a prior release from an older mortgage, remained encumbered under the subsequent mortgage contract. Consequently, the seizure via writ of replevin was legal, negating any claim for damages. The ancillary claim regarding an alleged illegal private sale of the trucks was also dismissed for lack of evidentiary support. The ruling underscores the principle that the Supreme Court is not a trier of facts.