Factual findings seldom disturbed by Supreme Court

Basic is the rule that factual findings of the trial court, affirmed by the Court of Appeals, are binding and conclusive upon this Court. As elucidated in Sta. Ana, Jr. v. Hernandez, viz.:

The credibility of witnesses and the weighing of conflicting evidence are matters within the exclusive authority of the Court of Appeals x x x. Both the Judiciary Act [now The Judiciary Reorganization Act of 1980] x x x and the Rules of Court x x x only allow a review of decisions of the Court of Appeals on questions of law; and numerous decisions of this Court have invariably and repeatedly held that findings of fact by the Court of Appeals are conclusive and not reviewable by the Supreme Court x x x x Barring, therefore, a showing that the findings complained of are totally devoid of support in the record, and that they are so glaringly erroneous as to constitute serious abuse of discretion, such findings must stand, for this Court is not expected or required to examine and contrast the oral and documentary evidence submitted by the parties. As pointed out by former Chief Justice Moran in his Comments on the Rules of Court x x x, the law creating the Court of Appeals was intended mainly to take away from the Supreme Court the work of examining the evidence, and confine its task for the determination of questions which do not call for the reading and study of transcripts containing the testimony of witnesses.

An issue is factual when the doubt or difference arises as to the truth or falsehood of alleged facts, or when the query invites calibration of the whole evidence considering mainly the credibility of witnesses, existence and relevancy of specific surrounding circumstances, their relation to each other and to the whole, and the probabilities of the situation. On the other hand, an issue is one of law when the doubt or difference arises as to what the law is on a certain state of facts. The issues of whether petitioner received respondents request for transfer by facsimile transmission or not and whether it was negligent in allowing the pretermination by Basilia Templa notwithstanding such receipt, are factual. (G.R. No. 166878; December 18, 2007)