GR 169801; (September 2007) (Digest)
G.R. No. 169801; September 11, 2007
REPUBLIC OF THE PHILIPPINES, represented by the DEPARTMENT OF HEALTH-REGIONAL HEALTH OFFICE NO. 3, Petitioner, vs. DONATILLA R. BAUTISTA, doing business under the name and style “RESCUE SECURITY SERVICES” and ELENA R. PALMA, Branch Manager, Respondents.
FACTS
The Department of Health (DOH) engaged Rescue Security Services to guard its premises under a Contract of Security Services effective January 1, 1996. On April 8, 1996, a robbery was discovered at a DOH storeroom, resulting in the loss of medicines valued at millions of pesos. The DOH subsequently notified Rescue Security and later terminated the contract, demanding payment for the loss based on the security agency’s contractual undertaking to guarantee payment for any loss or damage to the client’s property.
Rescue Security refused payment. The DOH filed an action for damages. The Regional Trial Court (RTC) dismissed the complaint, finding that while a loss occurred, the DOH failed to prove the medicines were under the security agency’s control due to a lack of a furnished inventory. The RTC also concluded the DOH failed to notify Rescue Security of the loss within the 48-hour period required by the contract. The Court of Appeals affirmed the dismissal, specifically upholding the finding on the breach of the 48-hour notice requirement, despite differing on the inventory issue.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the complaint based on the finding that the petitioner failed to comply with the contractual 48-hour notice requirement for reporting the loss.
RULING
No. The Supreme Court denied the petition and affirmed the lower courts’ decisions. The legal logic rests on the principle that factual findings of the Court of Appeals are binding and conclusive upon the Supreme Court in a Rule 45 petition, which is limited to reviewing errors of law. The Court found no compelling reason to deviate from this doctrine, as the petitioner failed to establish that the appellate court’s factual conclusion fell under any recognized exception.
The Court of Appeals’ finding—that the DOH did not provide the required notice within 48 hours—was based on its assessment of conflicting testimonial evidence. Specifically, it deduced from a letter sent by the DOH dated July 5, 1996, that the agency was notified only after a significant delay, not immediately upon discovery. The contractual condition for notification was deemed unfulfilled. Since the petitioner’s arguments essentially asked the Supreme Court to re-evaluate and weigh this evidence anew, which is a factual inquiry beyond the scope of a certiorari review, the Court upheld the appellate court’s factual determination. The breach of this contractual condition provided a sufficient legal basis for the dismissal of the claim for damages.