Tuesday, August 13, 2024

Question of Law

 "A "question of law" exists when the doubt hinges on what the law is on a certain set of facts or circumstances; on the other hand, there is a "question of fact" when the issue raised on appeal pertains to the truth or falsity of the alleged facts. The test for determining whether the supposed error was one of "law" or "fact" is not the appellation given by the parties raising the same; rather, it is whether the reviewing court can resolve the issues raised without evaluating the evidence, in which case, it is a question of law; otherwise, it is one of fact. In other words, where there is no dispute as to the facts, the question of whether the conclusions drawn from these facts are correct is a question of law. If the question posed, however, requires a re-evaluation of the credibility of witnesses, or the existence or relevance of surrounding circumstances and their relationship to each other, the issue is factual.47

Here, the first question of whether the trial court committed reversible error when it applied the 2019 Amendments to resolve the affirmative defenses pleaded by the respondent companies, albeit the same was already pending when these Amendments took effect is one of law. In Central Realty and Development Corp. v. Solar Resources, Inc.,48 the Court held that the issue of whether the trial court correctly applied a specific law or rules to a particular case is a question of law, viz.:


Was the denial of petitioner's motion for judgment on the pleadings correct? Is Solar's action for specific performance barred by res judicata? Is summary judgment in the case proper? These are precisely the questions being raised here. The resolution of these questions rests solely on what the law or the rules provides on the given set of circumstances. In other words, the Court ought to look only into whether the trial court correctly applied the law or rules in the case. These are pure questions of law which do not require the examination of evidence. (Emphasis supplied)"

[ G.R. No. 252467, June 21, 2021 ]

FRANK COLMENAR, IN HIS CAPACITY AS AN HEIR OF THE LATE FRANCISCO COLMENAR,* PETITIONER, VS. APOLLO A. COLMENAR, JEANNIE COLMENAR MENDOZA, VICTORIA JET COLMENAR, PHILIPPINE ESTATES CORPORATION, AMAIA LAND CORPORATION, CRISANTA REALTY DEVELOPMENT CORPORATION, PROPERTY COMPANY OF FRIENDS, AND THE REGISTER OF DEEDS OF THE PROVINCE OF CAVITE, RESPONDENTS.

https://lawphil.net/judjuris/juri2021/jun2021/gr_252467_2021.html