Tuesday, March 31, 2015

When the Supreme Court may review findings of fact by the lower courts

G.R. No. 173988, October 8, 2014
FELINA ROSALDES, Petitioner,  vs. PEOPLE OF THE PHILIPPINES, Respondent.



"x x x.
It is true that the limitation of the review to errors of law admits of exceptions. Under Section 4, Rule 3 of the Internal Rules of the Supreme Court, the following situations are the exceptions in which the Court may review findings of fact by the lower courts, to wit: (a) the conclusion is a finding grounded entirely on speculation, surmise and conjecture; (b) the inference made is manifestly mistaken; (c) there is grave abuse of discretion; (d) the judgment is based on a misapprehension of facts; (e) the findings of fact are conflicting; (f) the collegial appellate courts went beyond the issues of the case, and their findings are contrary to the admissions of both appellant and appellee; (g) the findings of fact of the collegial appellate courts are contrary to those of the trial court; (h) said findings of fact are conclusions without citation of specific evidence on which they are based; (i) the facts set forth in the petition aswell as in the petitioner’s main and reply briefs are not disputed by the respondents; (j) the findings of fact of the collegial appellate courts are premised on the supposed evidence, but are contradicted by the evidence on record; and (k) all other similar and exceptional cases warranting a review of the lower courts’ findings of fact. A further exception is recognized when the CA manifestly overlooked certain relevant facts not disputed bythe parties, which, if properly considered, would justify a different conclusion.12 Yet, none of the exceptions applies herein.
x x x."