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    Tabuena Vs CA

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    Andrew M. Acedera
    The Supreme Court ruled that decisions and factual findings cannot be based on evidence that was not formally offered. In this case, the trial court relied on exhibits and evidence from another case that were not formally submitted as evidence by the private respondent based on the Rules of Court. As a result, the factual findings of the trial court lacked a valid basis and should not have been sustained by the Court of Appeals. The Supreme Court found that the private respondent failed to prove ownership of the disputed property with properly submitted evidence, while the petitioner presented substantial evidence supporting his claim.

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    Tabuena Vs CA

    Uploaded by

    Andrew M. Acedera
    237 views1 page
    The Supreme Court ruled that decisions and factual findings cannot be based on evidence that was not formally offered. In this case, the trial court relied on exhibits and evidence from another case that were not formally submitted as evidence by the private respondent based on the Rules of Court. As a result, the factual findings of the trial court lacked a valid basis and should not have been sustained by the Court of Appeals. The Supreme Court found that the private respondent failed to prove ownership of the disputed property with properly submitted evidence, while the petitioner presented substantial evidence supporting his claim.

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    evidence case

    Original Title

    15. Tabuena vs CA

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    The Supreme Court ruled that decisions and factual findings cannot be based on evidence that was not formally offered. In this case, the trial court relied on exhibits and evidence from another case that were not formally submitted as evidence by the private respondent based on the Rules of Court. As a result, the factual findings of the trial court lacked a valid basis and should not have been sustained by the Court of Appeals. The Supreme Court found that the private respondent failed to prove ownership of the disputed property with properly submitted evidence, while the petitioner presented substantial evidence supporting his claim.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    237 views1 page

    Tabuena Vs CA

    Uploaded by

    Andrew M. Acedera
    The Supreme Court ruled that decisions and factual findings cannot be based on evidence that was not formally offered. In this case, the trial court relied on exhibits and evidence from another case that were not formally submitted as evidence by the private respondent based on the Rules of Court. As a result, the factual findings of the trial court lacked a valid basis and should not have been sustained by the Court of Appeals. The Supreme Court found that the private respondent failed to prove ownership of the disputed property with properly submitted evidence, while the petitioner presented substantial evidence supporting his claim.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    Tabuena v.

    Court of Appeals
    196 SCRA 650
    Topic: Formal Offer of Evidence
    Facts: Juan Peralta Jr., the half-brother of petitioner Jose Tabuena, sold a
    parcel of land to Alfredo Tabernilla while the two were in the United States.
    Tabernilla returned to the Philippines and upon his request, the subject land
    was conveyed to him by Damasa, Peralta’s mother. The latter, however,
    requested that she be allowed to stay in said property to which Tabernilla
    agreed on the condition that she will pay all realty taxes. Damasa remained
    on the said land until her death, following which the petitioner, her son, took
    possession thereof. The complaint was filed upon Tabuena to surrender the
    property and the trial court ruled against petitioner. The petitioner faults the
    decision of the trial court, as affirmed by the respondent court, for lack of
    basis because the lower courts should not have taken into account evidence
    not submitted by the private respondent in accordance with the Rules of
    Court. Petitioner claimed that the court, in arriving at its factual findings,
    took cognizance of pieces of evidence which had been marked by the
    plaintiff but never formally submitted in evidence.
    Issue: Whether or not decisions/factual findings may be drawn from
    evidences which are not formally offered.
    Ruling: No. It is the policy of this Court to accord proper deference to the
    factual findings of the courts below and even to regard them as conclusive
    where there is no showing that they have been reached arbitrarily. The
    exception is where such findings do not conform to the evidence on record
    and appear indeed to have no valid basis to sustain their correctness, as in
    this case.
    The conclusions of the trial court were based mainly on exhibits of evidence,
    which had not been formally offered as evidence and therefore should have
    been totally disregarded, conformably to the Rules of Court. The trial court
    also erred when it relied on the evidence submitted in another civil case and
    took judicial notice thereof without the consent or knowledge of the
    petitioner, in violation of existing doctrine. Thus vitiated, the factual findings
    here challenged are as an edifice built upon shifting sands and should not
    have been sustained by the respondent court.
    The Supreme Court found that the private respondent, as plaintiff in the
    lower court, failed to prove his claim of ownership over the disputed property
    with evidence properly cognizable under our adjudicative laws. By contrast,
    Case Digests on Evidence Page 26
    there is substantial evidence supporting the petitioner's contrary contentions
    that should have persuaded the trial judge to rule in his favor and dismiss
    the complaint.

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