Here are selected January 2010 rulings of the Supreme Court of the Philippines on remedial law:
Appeal; factual findings of administrative agencies. We stress the settled rule that the findings of fact of administrative bodies, such as the SEC, will not be interfered with by the courts in the absence of grave abuse of discretion on the part of said agencies, or unless the aforementioned findings are not supported by substantial evidence. These factual findings carry even more weight when affirmed by the CA. They are accorded not only great respect but even finality, and are binding upon this Court, unless it is shown that the administrative body had arbitrarily disregarded or misapprehended evidence before it to such an extent as to compel a contrary conclusion had such evidence been properly appreciated. By reason of the special knowledge and expertise of administrative agencies over matters falling under their jurisdiction, they are in a better position to pass judgment thereon. A review of the petition does not show any reversible error committed by the appellate court; hence, the petition must be denied. Petitioner failed to present any argument that would convince the Court that the SEC and the CA made any misappreciation of the facts and the applicable laws such that their decisions should be overturned. Catmon Sales International Corporation vs. Atty. Manuel D. Yngson, Jr. as Liquidator of Catmon Sales International Corporation, G.R. No. 179761, January 15, 2010.
Appeal; factual findings of administrative agencies. No matter how hard it tries to learn the technical intricacies of certain highly regulated human activities, the Supreme Court will always be inadequately equipped to identify the facts that matter when resolving issues involving such activities. Invariably, the Court must respect the factual findings of administrative agencies which have expertise on matters that fall within their jurisdiction. Here, since the HLURB has the expertise in applying zonal classifications on specific properties and since petitioner GEA fails to make out a clear case that it has erred, the Court must rely on its finding that respondent EGI’s land site does not, for the purpose of applying height restrictions, adjoin an R-1 zone. Greenhills East Association, Inc. vs. E. Ganzon, Inc., G.R. No. 169741, January 22, 2010.
Appeal; factual findings of lower courts. In the case at bench, the issues raised by the petitioners are essentially factual matters, the determination of which are best left to the courts below. Well-settled is the rule that the Supreme Court is not a trier of facts. Factual findings of the lower courts are entitled to great weight and respect on appeal, and in fact accorded finality when supported by substantial evidence on the record. Substantial evidence is more than a mere scintilla of evidence. It is that amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion, even if other minds, equally reasonable, might conceivably opine otherwise. But to erase any doubt on the correctness of the assailed ruling, we have carefully perused the records and, nonetheless, arrived at the same conclusion. We find that there is substantial evidence on record to support the Court of Appeals and trial court’s conclusion that the signatures of Julian and Guillerma in the Deed of Absolute Sale were forged. Spouses Patricio and Myrna Bernales vs. Heirs of Julian Sambaan, et al., G.R. No. 163271, January 15, 2010.
Appeal; factual findings of lower courts. Conclusions and findings of fact by the trial court are entitled to great weight on appeal and should not be disturbed unless for strong and cogent reasons because the trial court is in a better position to examine real evidence, as well as to observe the demeanor of the witnesses while testifying in the case. The fact that the CA adopted the findings of fact of the trial court makes the same binding upon this court. In Philippine Airlines, Inc. v. Court of Appeals, we held that factual findings of the CA which are supported by substantial evidence are binding, final and conclusive upon the Supreme Court. A departure from this rule may be warranted where the findings of fact of the CA are contrary to the findings and conclusions of the trial court, or when the same is unsupported by the evidence on record. There is no ground to apply the exception in the instant case, however, because the findings and conclusions of the CA are in full accord with those of the trial court. Spouses Patricio and Myrna Bernales v. Heirs of Julian Sambaan, et al., G.R. No. 163271, January 15, 2010.