Maglana Rice and Corn Mill, Inc. vs. Tan

A petition for review on certiorari under Rule 45 must raise only questions of law; an appeal that raises purely factual issues already uniformly resolved by lower courts is frivolous and warrants the imposition of treble costs of suit.

On August 28, 1996, a Fuso truck owned by Maglana Rice and Corn Mill, Inc. and driven by its employee Ramon P. Dao collided with the rear of a Honda Accord sedan owned by Annie L. Tan and driven by Manuel Tan along the Davao-Agusan Road in Lanang, Davao City. The respondents demanded reimbursement for vehicle repair expenses, but the petitioners denied liability, prompting the filing of a complaint in the Municipal Trial Court in Cities.

• The Collision: The respondents' car was travelling along the Davau-Agusan Road and had to stop upon reaching the All Trac Compound due to traffic congestion caused by an earlier collision. Dao, driving the petitioners' truck, failed to stop and bumped the car at its rear, causing material damage valued at ₱83,750.00. The respondents' version was corroborated by the traffic accident report and the court testimony of traffic investigator SPO4 Manuel C. Española.
• Petitioners' Version: Dao claimed he was observing a three-car distance at 30 km/h and decelerated upon seeing the earlier accident. He alleged that the respondents' car overtook his truck from the right lane and suddenly cut into his lane at an unsafe distance, causing the right front of the truck to hit the left rear of the car while the car was in a diagonal position.
• Lower Courts' Factual Findings: The MTCC, RTC, and CA uniformly accorded greater credence to the respondents' version. Pictorial evidence revealed no scraping marks or dents on the left side of the car, only solitary material damage on the left rear, proving a single collision occurred because the truck hit the stopped car. The police report was deemed unbiased, and Dao's lack of foresight and vigilance was established as the proximate cause.

• Violation of Traffic Rules: Petitioner argued that respondent Manuel Tan violated traffic rules under Section 39 of Republic Act No. 4136 and was negligent pursuant to Article 2185 of the Civil Code.
• Malicious Motive: Petitioner maintained that Tan was covering up his misdeeds because the car's insurance had expired and he intended to burden the truck's insurance with the repair expenses.
• Erroneous Police Report: Petitioner contended that the police report was erroneous and biased in favor of the respondents, a perception allegedly shared by the original MTCC presiding judge who retired before rendering a decision.
• Misappreciation of Evidence: Petitioner argued that the lower courts erred in their appreciation of the evidence, resulting in an erroneous conclusion.

• Nature of the Appeal: Whether the petition for review on certiorari raises a question of law or a question of fact.
• Factual Findings of Lower Courts: Whether the uniform factual findings of the MTCC, RTC, and CA should be disturbed.
• Frivolous Appeal: Whether the appeal is frivolous, warranting the imposition of treble costs of suit.

• Nature of the Appeal: The petition raises purely factual issues regarding the cause of the vehicular accident and driver negligence, which are not reviewable under Rule 45. A question of law must not involve an examination of the probative value of the evidence presented by the litigants; determining which driver was negligent requires an examination of the truth or falsehood of alleged facts.
• Factual Findings of Lower Courts: The uniform factual findings of the MTCC, RTC, and CA are binding. No exception to the rule applies, as the lower courts' findings were consistent and based on substantial evidence, such as the pictorial evidence showing only rear damage and the unbiased police report.
• Frivolous Appeal: The appeal is frivolous because it presents no justiciable question and is devoid of merit, having been filed despite the purely factual nature of the issues. Treble costs of suit were imposed pursuant to Section 3, Rule 142 of the Rules of Court to sanction the unwarranted prolongation of litigation and to remind petitioners and their counsel of the reasonable limits of professional responsibility.

• Question of Law vs. Question of Fact — A question of law arises when the doubt or difference concerns what the law is on a certain state of facts; a question of fact arises when the doubt or difference concerns the truth or falsehood of alleged facts. Whether evidence should be accorded probative value or weight, or whether proofs are clear and convincing, are issues of fact not reviewable by the Supreme Court under Rule 45.
• Exceptions to the Rule on Questions of Law in Rule 45 — The Supreme Court may review factual issues if: (a) findings are based on speculation, surmises, or conjectures; (b) the inference made is manifestly mistaken, absurd, or impossible; (c) there is grave abuse of discretion; (d) the judgment is based on a misapprehension of facts; (e) the findings of facts are conflicting; (f) the CA went beyond the issues of the case or its findings are contrary to the admissions of both parties; (g) the findings are contrary to those of the trial court; (h) the findings are conclusions without citation of specific evidence; (i) the facts set forth in the petition and briefs are not disputed by the respondent; (j) the findings of fact are premised on the supposed absence of evidence and contradicted by the evidence on record; and (k) the CA manifestly overlooked certain relevant facts not disputed by the parties which, if properly considered, would justify a different conclusion.
• Frivolous Appeal — An appeal is frivolous where no error can be brought before the appellate court, or whose result is obvious and the arguments of error are totally bereft of merit, or which is prosecuted in bad faith, or which is contrary to established law and unsupported by a reasoned, colorable argument for change. It is likewise frivolous when it does not present any justiciable question or is so readily recognizable as devoid of merit on the face of the record that there is little prospect it can succeed.

• "A question, to be one of law, must not involve an examination of the probative value of the evidence presented by the litigants or any of them. Indeed, there is a question of law in a given case when the doubt or difference arises as to what the law is on certain state of facts; there is a question of fact when the doubt or difference arises as to the truth or falsehood of alleged facts."
• "A frivolous appeal is one where no error can be brought before the appellate court, or whose result is obvious and the arguments of error are totally bereft of merit, or which is prosecuted in bad faith, or which is contrary to established law and unsupported by a reasoned, colorable argument for change."

• Paterno v. Paterno, G.R. No. 63680, March 23, 1990, 183 SCRA 630 — Followed for the definition distinguishing questions of fact from questions of law.
• Sampayan v. Court of Appeals, G.R. No. 156350, January 14, 2005, 448 SCRA 220 — Followed for the enumeration of exceptions allowing the Supreme Court to review factual issues in a petition for review on certiorari.
• De La Cruz v. Blanco and Quevedo, 73 Phil. 596 (1942) — Followed for the definition of a frivolous appeal.

• Section 1, Rule 45, Rules of Court — Provides that a petition for review on certiorari shall raise only questions of law, which must be distinctly set forth. Applied to dismiss the petition for raising purely factual issues of negligence.
• Section 3, Rule 142, Rules of Court — Authorizes the imposition of double or treble costs where an action or appeal is found to be frivolous. Applied to impose treble costs on the petitioners.
• Section 39, Republic Act No. 4136 — Referenced by petitioners regarding traffic rule violations, but not substantively applied due to the factual nature of the dispute.
• Article 2185, Civil Code — Referenced by petitioners regarding negligence arising from violation of traffic rules, but not substantively applied due to the factual nature of the dispute.

Renato C. Corona, Teresita J. Leonardo-De Castro, Mariano C. Del Castillo, Jose Portugal Perez