G.R. No. 159051 ; September 21, 2011
MAGLANA RICE AND CORN MILL, INC., and RAMON P. DAO, Petitioners, vs. ANNIE L. TAN and her husband MANUEL TAN, Respondents.

FACTS

This case originated from a vehicular accident on August 28, 1996, along the Davao-Agusan Road in Lanang, Davao City, involving a Fuso truck owned by petitioner Maglana Rice and Corn Mill, Inc. and driven by its employee, petitioner Ramon P. Dao, and a Honda Accord sedan owned by the respondents and driven by respondent Manuel Tan. The truck hit the car at its rear, causing damage to both vehicles. The respondents demanded reimbursement for repair expenses, which the petitioners refused, leading to the filing of a complaint in the Municipal Trial Courts in Cities (MTCC) of Davao City.
The respondents’ version, corroborated by a traffic accident report and the testimony of traffic investigator SPO4 Manuel C. Española, was that their car had to stop due to a traffic slowdown caused by an earlier collision ahead. Dao, driving the truck, failed to stop and bumped the stationary car from behind, causing material damage valued at ₱83,750.00.
The petitioners presented a different account: Dao was driving in the inner north-bound lane at about 30 km/h, maintaining a distance of three car lengths. Upon spotting an accident ahead, he slowed down. The respondents’ car then overtook the truck from the right lane and suddenly cut into his lane at an unsafe distance, causing the right front portion of the truck to contact the left rear of the car.
The MTCC found the respondents’ version more credible and ruled that the proximate cause of the accident was Dao’s lack of foresight and vigilance. It held the petitioners jointly and severally liable for ₱83,750.00 in repair costs, ₱15,000.00 in attorney’s fees, and costs of suit. The Regional Trial Court (RTC) and the Court of Appeals (CA) affirmed the MTCC’s decision. The petitioners elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the petition for review on certiorari, which raises the factual issue of which driver was negligent and caused the vehicular accident, is proper given that such an appeal is limited to questions of law.

RULING

The Supreme Court DENIED the petition. The appeal was outrightly rejected.
The Court held that the core issue—determining which driver was negligent and the real cause of the accident—is a question of fact. A petition for review on certiorari under Rule 45 of the Rules of Court is strictly limited to questions of law. A question of law exists when the doubt concerns what the law is on a given set of facts, while a question of fact exists when the doubt concerns the truth or falsity of alleged facts. The assessment of the probative value of evidence, the credibility of witnesses, and the resolution of conflicting factual accounts are functions of the trial courts, whose factual findings are generally binding and not subject to review by the Supreme Court.
The Court enumerated recognized exceptions where factual review may be undertaken (e.g., when findings are grounded on speculation, are manifestly mistaken, or when there is grave abuse of discretion). However, it found that none of these exceptions applied in this case. Three lower courts (MTCC, RTC, and CA) consistently found the respondents’ version, supported by the police report, to be credible and that the petitioners’ truck was the proximate cause of the accident.
Furthermore, the Court deemed the appeal frivolous and imposed treble costs of suit against the petitioners for pursuing a clearly unmeritorious appeal that raised factual issues not reviewable by the Supreme Court, thereby burdening the judicial system. The decisions of the lower courts were affirmed in toto.