GR 149875; (April, 2007) (Digest)
G.R. No. 149875; April 2, 2007
AMA COMPUTER COLLEGE, INC., Petitioner, vs. ATTY. A. D. VALMONTE, Respondent.
FACTS
AMA Computer College, Inc. (AMA) filed a complaint for the suspension of Atty. A.D. Valmonte from the practice of law before the Regional Trial Court (RTC). AMA alleged that it had a lease contract with Emilio Tayao over a parcel of land, which included an option to purchase. When AMA sought to exercise this option, Tayao allegedly obtained a loan from FELN International Corporation secured by simulated promissory notes. Upon Tayao’s default, FELN, represented by Atty. Valmonte, filed a collection case. A compromise judgment was rendered, leading to the levy on execution of the building occupied by AMA. AMA contended that Atty. Valmonte committed fraudulent acts by filing a “mock action” based on fictitious notes to frustrate AMA’s option to purchase.
The RTC dismissed AMA’s complaint and, upon Atty. Valmonte’s counterclaim, awarded him moral damages and attorney’s fees, finding that the suit unjustly maligned his professional reputation. The Court of Appeals affirmed the RTC decision but reduced the amounts awarded. AMA elevated the case to the Supreme Court via a petition for review on certiorari, arguing the appellate court erred in finding the complaint was filed in bad faith and in awarding damages.
ISSUE
Whether the Supreme Court can review the factual findings of the lower courts in this petition for review on certiorari.
RULING
The Supreme Court denied the petition. The Court emphasized that a petition for review on certiorari under Rule 45 of the Rules of Court is limited to reviewing questions of law, not questions of fact. The factual findings of the trial court, especially when affirmed by the Court of Appeals, are generally binding and conclusive upon the Supreme Court.
AMA’s petition essentially sought a re-evaluation of the evidence, asking the Court to reassess the alleged simulation of the promissory notes, the existence of FELN, and the nature of the collection suit. These are quintessential questions of fact. The Supreme Court found no compelling reason to deviate from this rule, as none of the recognized exceptions warranting a factual review were present. Consequently, the Court upheld the findings of the lower courts that AMA’s complaint for suspension was unfounded and filed in bad faith, justifying the award of damages to Atty. Valmonte for the injury to his professional standing. The assailed decision was affirmed.