GR 152262; (February, 2012) (Digest)
G.R. No. 152262 ; February 15, 2012
FELIMON MANGUIOB, Petitioner, vs. JUDGE PAUL T. ARCANGEL, RTC, BRANCH 12, DAVAO CITY and ALEJANDRA VELASCO, Respondents.
FACTS
Petitioner Felimon Manguiob and respondent Alejandra Velasco formed a partnership, Baculin Enterprises, on May 3, 1994. Velasco was the capitalist partner, while Manguiob was the industrial partner managing operations. The partnership dissolved on September 14, 1994. Velasco filed a complaint for sum of money, accounting, and damages, alleging Manguiob failed to return her capital contribution and share in the profits. She claimed her capital was ₱320,000 and that an audit showed a net profit of ₱252,673.50, entitling her to 60%. Manguiob countered that the capital was only ₱200,000 and denied liability.
The parties submitted a Partial Stipulation of Facts, agreeing on the dissolution date and total sales figures but leaving specific issues for resolution: the exact capital contribution, the amount of sales proceeds returned, the net profit, and claims for damages. The Regional Trial Court (RTC) ruled in favor of Velasco, finding her capital contribution was ₱400,000 and ordering Manguiob to pay ₱498,245.52. The Court of Appeals (CA) affirmed but recalculated the amount due.
ISSUE
The core issue was whether the CA erred in its factual determination of the amounts due to Velasco, specifically concerning her capital contribution and share in the partnership profits.
RULING
The Supreme Court denied the petition, affirming the CA’s decision with modification. The Court emphasized that a petition for review under Rule 45 must raise only questions of law, not questions of fact. Manguiob’s arguments challenging the lower courts’ evaluation of evidence—such as the credibility of receipts and the computation of capital and profits—were factual in nature. Factual findings of the trial court, especially when affirmed by the CA, are binding and conclusive on the Supreme Court.
The legal logic rests on the finality of factual determinations made by lower courts when supported by substantial evidence. The RTC and CA meticulously examined the evidence, including receipts and testimonies, to establish that Velasco’s capital was ₱400,000. The courts correctly applied partnership law principles on liquidation, ensuring the capitalist partner’s contribution is returned and profits are distributed according to the agreed ratio (60/40) after accounting for all assets and liabilities. The Supreme Court modified the CA’s award to ₱398,245.52, representing the balance of Velasco’s capital plus her 60% profit share, based on a precise recalculation from the stipulated sales data and the uncontested amount of sales proceeds she retained. The deletion of attorney’s fees was upheld.