G.R. No. 75450 NOVEMBER 8, 1990
OSMUNDO MEDINA, ET AL., petitioners, vs. HON. MACARIO A. ASISTIO, JR., AS MAYOR OF CALOOCAN CITY AND JOSE E.R. USON AS CITY ENGINEER OF CALOOCAN CITY, respondents.

FACTS

Petitioners are residents of Marulas-A, Caloocan City, a parcel of land owned by the Philippine National Railways (PNR). They claim to be long-time legitimate tenants and sub-tenants of the PNR. After a fire in August 1980 destroyed their dwellings, they reconstructed their houses, allegedly with authorization from respondent Mayor Asistio. In February 1982, PNR sold the lot to the City Government of Caloocan for the construction of a school building. Petitioners, facing eviction, sent letters to the Mayor seeking to continue occupancy or to purchase the property under P.D. No. 1517 (Urban Land Reform Law). A compromise dialogue failed, and on February 1, 1985, respondent City Engineer issued a final notice for petitioners to demolish their houses for illegally occupying government property, pursuant to LOI No. 19.

ISSUE

Whether the Court of Appeals erred in its factual findings that petitioners, except for Medina, are squatters who built houses without permits on public property, and whether these findings are reviewable by the Supreme Court.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals’ decision with modification. The legal logic is anchored on the distinction between questions of law and questions of fact. Petitioners’ assignment of errors challenges the appellate court’s factual findings and appreciation of evidence, such as their status as legitimate tenants and the legality of their constructions. Under established jurisprudence, the Supreme Court’s jurisdiction is generally limited to reviewing errors of law. A question of law arises when the doubt concerns the application or interpretation of law, while a question of fact exists when the doubt pertains to the truth or falsehood of alleged facts. Here, petitioners essentially ask the Court to re-examine and re-weigh the evidence, which involves a question of fact beyond the Court’s scope of review in a petition for review on certiorari. The Court cited precedents like Sotto v. Teves, emphasizing that findings of fact by the Court of Appeals are conclusive and not reviewable. Petitioners’ reliance on Cunanan v. Lazatin was misplaced, as that case involved conclusions drawn from proven facts, whereas here, the facts themselves were disputed and required evidentiary assessment. However, the Court modified the decision by exempting petitioners Medina, Gatchalian, and Banzuela from the demolition order, as their houses were found to be outside the respondents’ territorial jurisdiction. The Court also noted that general moratoriums on eviction under P.D. No. 2016 and related issuances were inapplicable as the property was already under litigation.