G.R. No. L-17490; February 27, 1962
LAZARO MOSSO, plaintiff-appellant, vs. UY KEE BENG, Owner-Manager, of the Uy Kee Beng Hardware, defendant-appellee.

FACTS

Lazaro Mosso filed a claim with the Department of Labor for compensation, separation, and overtime pay for services rendered to Uy Kee Beng Hardware from April 1946 to August 1956. After a hearing officer dismissed the claim, an Associate Commissioner of the Labor Standards Commission reversed the dismissal and awarded Mosso P14,403.16 for overtime. On appeal en banc, the Commission reduced the award to P5,315.54. Uy Kee Beng then appealed to the Court of First Instance of Manila, which dismissed Mosso’s complaint, finding the defense evidence more credible.
Mosso appealed to the Supreme Court but later filed a motion stating his intent was to appeal to the Court of Appeals and requesting remand. The Supreme Court denied this motion and a subsequent petition for reconsideration. Mosso then filed his brief, arguing the trial court’s decision was contrary to law and constituted a grave abuse of discretion. He specifically contended that the daily time records relied upon by the defense were obtained through threats and contained false entries, and that the testimony of the appellee and his witnesses was unworthy of credence.

ISSUE

Whether the Supreme Court has appellate jurisdiction to review the factual findings of the Court of First Instance in this case.

RULING

The Supreme Court ruled it lacked appellate jurisdiction and ordered the case certified to the Court of Appeals. The legal logic is grounded on the statutory distribution of appellate jurisdiction based on the nature of the questions raised and the amount involved. Mosso’s appeal challenged the trial court’s evaluation of evidence, specifically the credibility of witnesses and the authenticity of daily time records. These are quintessential questions of fact.
Under Section 31 of Republic Act No. 296 (The Judiciary Act of 1948), as amended, the Supreme Court’s jurisdiction over appeals from courts of first instance is limited. It has exclusive jurisdiction over cases where only errors or questions of law are involved. Conversely, the Court of Appeals has jurisdiction over appeals where questions of fact or mixed questions of law and fact are raised, provided the amount involved exceeds a certain statutory threshold. Since the monetary award in question was P5,315.54 and the appeal squarely presented factual issues, the case fell within the appellate jurisdiction of the Court of Appeals. The Supreme Court, therefore, could not pass upon the merits of the factual disputes and was duty-bound to transfer the case to the proper forum.