SAN MIGUEL FOODS, INC., vs SPOUSES RAMON AND MA. NELIA FABIE, AND FRESH LINK, INC., G.R. No. 234849, April 03, 2024

The Court can conduct its own factual findings if there is insufficient evidence or if the parties failed to substantiate their claims

In civil cases, the party having the burden of proof must establish its cause of action by a preponderance of evidence,³¹ or that "evidence which is of greater weight or is more convincing than that which is in opposition to it." ³²

Preponderance of evidence "does not mean absolute truth; rather, it means that the testimony of one side is more believable than that of the other side, and that the probability of truth is on one side than on the other."³³

A determination of where the preponderance of evidence lies constitutes a factual matter, which, as a rule, cannot be considered in a Rule 45 petition.³⁴

This is because the Court is not a trier of facts; the function of the Court in petitions for review on certiorari under Rule 45 of the Rules of Court is limited to reviewing errors of law that may have been committed by the lower courts.

However, there are exceptions to this rule, including instances where:

(1) the conclusion is a finding grounded entirely on speculation, surmise, and conjectures;

(2) the inference made is manifestly mistaken;

(3) there is grave abuse of discretion;

(4) the judgment is based on misapprehension of facts; and

(5) the findings of fact are premised on the absence of evidence and are contradicted by evidence on record.³⁵

Here, the lower courts' decisions rest heavily on the testimony of one witness, namely Nelia Fabie. Thus, this Court will embark on its own factual analysis and will, if necessary, reverse the rulings of the lower courts if the facts of the case suggest a lack or absence of evidence consistent with the fifth exception cited above, or if it finds that respondents in this case have failed to substantiate their claims by preponderance of evidence and, thus, are not entitled to the award of damages.

FOOTNOTES

³² Bank of the Philippinelslands v. Reyes, 568 Phil. 188, J 97 (2008) [Per J. Austria-Martinez, Third Division].

³³ Id.; Cathay Pacific Steel Corp. v. Uy, Jr., G.R. No. 219317, June 14, 2021 [PerJ. Hernando, Third Division].

³⁴ DST Movers Corp. v. People's General Insurance Corp., 778 Phil. 235,238 (2016) [Per J. Leonen, Second

Division].

³⁵ Heirs of Villanueva v. Heir ofSyquia Mendoza, 810 Phil. 172, 178-179 (2017) [Per J. Peralta, Second

Division].

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