G.R. No. L-42626 December 8, 1982
ANITA G. TORRES and LAZARO TORRES, petitioners, vs. NORA S. YU, JOSE B. YU and COURT OF APPEALS, respondents.

FACTS

The Municipal Court of Lingayen, Pangasinan, in an ejectment suit, ordered the Yu spouses to vacate a portion of a market stall and pay monthly rentals to the Torres spouses. The Yu spouses appealed to the Court of First Instance (CFI), which affirmed the municipal court’s decision. After their motion for reconsideration was denied, the Yu spouses filed a petition for review with the Court of Appeals (CA). The CA gave due course to the petition. The Torres spouses then filed a special civil action for certiorari with the Supreme Court, contending that the CA had no jurisdiction to review the CFI decision under Republic Act No. 6031 . They argued that the issue of whether the CFI’s factual findings were supported by substantial evidence was a purely legal question falling within the Supreme Court’s exclusive jurisdiction.

ISSUE

Whether the Court of Appeals has jurisdiction under Republic Act No. 6031 to review, via petition for review, a decision of the Court of First Instance which affirmed in full the judgment of an inferior court in a case exclusively cognizable by that inferior court.

RULING

Yes, the Court of Appeals has jurisdiction. The legal logic examines the legislative history of appellate review. Initially, under the unamended Judiciary Law, all CFI decisions involving factual issues were appealable to the CA as a matter of right. To avoid protracted litigation in cases originating from inferior courts, like ejectment cases, Republic Act No. 5433 was enacted. It provided that CFI decisions affirming inferior court judgments could be elevated to the CA only by petition for review, entertainable only upon a prima facie showing of errors of fact or law warranting reversal or modification. Republic Act No. 6031 later amended Section 45 of the Judiciary Law, stating that CFI decisions in cases exclusively cognizable by inferior courts shall be final unless the findings of fact are not supported by substantial evidence or the conclusions are clearly against law and jurisprudence. The Court harmonized these laws, ruling that R.A. 6031 did not divest the CA of jurisdiction but merely established a specific standard for finality. The petition for review to the CA remains the proper procedural vehicle to challenge such finality. Since the Yu spouses’ petition essentially questioned the evidential support of the CFI’s findings—a factual inquiry—the CA correctly assumed jurisdiction. The Supreme Court’s certiorari jurisdiction over pure questions of law remains intact but is not invoked when the core issue requires evidence evaluation.