You are on page 1of 4

TO

:
FROM
:
DATE
:
RE
:

Factual findings of lower courts binding on the


SC; NLRC - CA established facts controlling as
a general rule; authorities

The Supreme Court is bound by


the factual findings of the
NLRC and the CA.
Absent any showing that the Labor Arbiter, the NLRC
or the Court of Appeals gravely abused its discretion
or otherwise acted without jurisdiction or in excess of
the same, this Court is bound by its findings of facts.
Indeed, the records reveal that the questioned decision is
duly supported by evidence. Findings of facts of quasijudicial agencies like the NLRC are accorded by this
Court not only with respect but even finality if they
are supported by substantial evidence, or that amount
of relevant evidence which a reasonable mind might accept
as adequate to justify a conclusion. This quantum of proof
has been satisfied in this case. These are, on the main,
factual findings over which the Labor Arbiter and the
NLRC are most equipped to determine having
acquired expertise in the specific matters entrusted
to their jurisdiction.
[Nueva
Ecija
Electric
Cooperative (NEECO) II v.
National
Labor
Relations
Commission, 461 SCRA 169,
184-185.
G.R. No. 157603,
June 23, 2005.]
The well-entrenched rule, especially in labor cases, is
that findings of fact of quasi-judicial bodies, like the
National Labor Relations Commission (NLRC), are
accorded with respect, even finality, if supported by
substantial evidence. Particularly when passed upon

and upheld by the Court of Appeals, they are binding


and conclusive upon the Supreme Court and will not
normally be disturbed.
xxx
This petition mainly involves factual issues, i.e., whether or
not there is evidence on record to support the findings of the
Labor Arbiter, the NLRC and the Court of Appeals that
respondent is entitled to the payment of salary differential
and unpaid wages. This calls for a re-examination of the
evidence, which the Court cannot entertain. As stated
earlier, factual findings of labor officials, who are
deemed to have acquired expertise in matters within
their respective jurisdiction, are generally accorded
not only respect but even finality, and bind the Court
when supported by substantial evidence. It is not the
Courts function to assess and evaluate the evidence
all over again, particularly where the findings of both
the Arbiter and the Court of Appeals concur.
[G & M (Phils.), Inc. v. Cruz,
456 SCRA 215, 217-220. G.R.
No. 140495 April 15, 2005.]
At the outset, we must stress that only errors of law are
generally reviewed by this Court in petitions for review on
certiorari of CA decisions. Questions of fact are not
entertained. After all, this Court is not a trier of facts
and, in labor cases, this doctrine applies with greater
force. Factual questions are for labor tribunals to
resolve. The findings of fact of quasi-judicial bodies
like the NLRC, are accorded with respect, even
finality, if supported by substantial evidence.
Particularly when passed upon and upheld by the
Court of Appeals, they are binding and conclusive upon the
Supreme Court and will not normally be disturbed.
[San Juan De Dios Educational
Foundation Employees UnionAlliance of Filipino Workers v.
San Juan De Dios Educational
Foundation, Inc., 430 SCRA

193, 205-206.
G.R.
143341 May 28, 2004.]

No.

The Supreme Court is not a


trier of facts.
Exceptions to
the rule.
Well-settled is the rule that this Court is not a trier of
facts. When supported by substantial evidence, the
findings of fact of the CA are conclusive and binding,
and are not reviewable by this Court, unless the case
falls under any of the following recognized exceptions:
1. When the conclusion is a finding grounded entirely on
speculation, surmises and conjectures;
2. When the inference made is manifestly mistaken,
absurd or impossible;
3. Where there is a grave abuse of discretion;
4. When the judgment is based on a misappreciation of
facts;
5. When the findings of fact are conflicting;
6. When the CA in making its findings, went beyond
the issues of the case and the same is contrary to the
admissions of both appellant and appellee;
7. When the findings are contrary to those of the trial
court;
8. When the findings of fact are conclusions without
citation of specific evidence on which they are based;
9. When the facts set forth in the petition as well as in the
petitioners main and reply briefs are not disputed by
the respondents; and
10. When the findings of fact of the CA are premised
on the supposed absence of evidence and
contradicted by the evidence on record.

None of these exceptions is present in this case. We find that


the Decision of the CA is supported by the required quantum
of evidence.
[Campos v. Pastrana, 608
SCRA 55, 63-63. G.R. No.
175994, December 8, 2009.]

You might also like