GR 155850; (February, 2008) (Digest)
G.R. No. 155850; February 19, 2008
EDGARDO POSTANES, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Two separate informations for slight physical injuries were filed following an altercation at Masagana City Mall in Pasay City on April 9, 1996. Petitioner Edgardo Postanes, a security coordinator, alleged that Remigio Pasion, without provocation, uttered offensive words and punched him, causing injuries that required hospital treatment. In the countercharge, Pasion claimed that Postanes was the aggressor, suddenly punching him, kicking him, and poking a gun at him, resulting in injuries that prevented him from working for ten days.
The Metropolitan Trial Court (MeTC), in a Joint Decision, acquitted Pasion but convicted Postanes of slight physical injuries, sentencing him to twenty days of imprisonment. The Regional Trial Court (RTC) affirmed this conviction on appeal. The Court of Appeals (CA) subsequently dismissed Postanes’s petition, upholding the lower courts’ findings, particularly giving probative value to Pasion’s duly authenticated medical certificate while rejecting Postanes’s for lack of authentication.
ISSUE
Whether the Court of Appeals erred in affirming petitioner’s conviction based on factual and credibility assessments, which are allegedly improper in a petition for review on certiorari under Rule 45.
RULING
The Supreme Court denied the petition. The Court emphasized that a petition for review on certiorari under Rule 45 is limited to questions of law; it does not permit a re-evaluation of factual findings or the credibility of witnesses, which are binding when supported by substantial evidence. Petitioner’s arguments—challenging the unequal treatment of medical certificates, the credibility of witnesses, and the fact that the deciding MeTC judge did not personally hear all testimonies—are inherently factual. The record substantiates the CA’s ruling: Pasion’s medical certificate was properly authenticated by the records custodian who testified, whereas Postanes’s certificate was not authenticated at all. Thus, no reversible error was committed. The findings of the trial courts, affirmed by the CA, stand as they are supported by the evidence on record.