G.R. No. 133056 ; August 28, 2001
FACUNDO T. BAUTISTA, petitioner, vs. PUYAT VINYL PRODUCTS, INC., respondent.

FACTS

Petitioner Facundo T. Bautista owned a fenced farm (Lot No. 326) in Mariveles, Bataan. Respondent Puyat Vinyl Products, Inc. operated a manufacturing plant on the adjoining lot (Lot No. 336). On April 15, 1994, Bautista filed a complaint for damages against the corporation, alleging that a grass fire originated from the respondent’s factory compound and crossed over to his farm, causing damage. In its answer, respondent contended that the grass fire occurred on January 22, 1994, and originated from the land adjoining its property when people clearing the area lit gathered grass materials, which then raged uncontrollably and also razed a portion of the respondent’s property. The Regional Trial Court ruled in favor of Bautista, awarding actual/compensatory damages, attorney’s fees, and costs. The Court of Appeals reversed the trial court’s decision and dismissed the complaint and the counterclaim.

ISSUE

The issues raised were: (1) whether the grass fire occurred on January 22, 1994, or January 29, 1994; (2) what was the precise origin of the fire; and (3) did the fire start from respondent’s factory and cross over to petitioner’s farm. These are factual issues.

RULING

The Supreme Court DENIED the petition and AFFIRMED the decision of the Court of Appeals in toto. The Court held that the issues raised are factual. In an appeal via certiorari, the Supreme Court may not review the findings of fact of the Court of Appeals when supported by substantial evidence, as they are conclusive and binding unless the case falls under recognized exceptions, which petitioner failed to prove. The Court emphasized that it is not a trier of facts and that questions of fact cannot be raised in an appeal via certiorari. Both the trial court and the Court of Appeals found no scintilla of evidence to prove that the grass fire resulted from the negligence of the respondent.