Administrative Law Philippines

Topics: Jury, Question of fact, Question of law Pages: 6 (2237 words) Published: November 18, 2012
1. Administrative Findings Given Great Weight in Court

Sebastian F. Oasay, Jr. vs. Palacio del Gobernador Condominium Corporation and Omar T. Cruz, [G.R. No. 194306, February 6, 2012.] LINK: Appeal; factual finding of NLRC. Findings of fact of administrative agencies and quasi-judicial bodies, which have acquired expertise because their jurisdiction is confined to specific matters, are generally accorded not only respect but finality when affirmed by the Court of Appeals. Factual findings of quasi-judicial bodies like the NLRC, if supported by substantial evidence, are accorded respect and even finality by the Supreme Court, more so when they coincide with those of the Labor Arbiter. Such factual findings are given more weight when the same are affirmed by the Court of Appeals. In the present case, the Supreme Court found no reason to depart from these principles since the Labor Arbiter found that there was substantial evidence to conclude that Oasay had breached the trust and confidence of Palacio Del Gobernador Condominium Corporation, which finding the NLRC had likewise upheld. 

Gatus vs. SSS [G. R. No. 174725, January 26, 2011]
LINK: The sole issue to be determined is whether the Court of Appeals committed grave abuse of discretion in affirming the finding of the ECC that petitioner’s ailment is not compensable under Presidential Decree No. 626, as amended. xxx

The burden of proof is thus on petitioner to show that any of the above conditions have been met in his case.  The required proof is further discussed in Ortega v. Social Security Commission[17]:  

The requisite quantum of proof in cases filed before administrative or quasi-judicial bodies is neither proof beyond reasonable doubt nor preponderance of evidence. In this type of cases, a fact may be deemed established if it is supported by substantial evidence, or that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. In this case, substantial evidence abounds.


The questioned Decision deemed as established fact that petitioner is a cigarette smoker; but petitioner vehemently denies this, saying there is no competent evidence to prove he had that habit.  What petitioner would like this Court to do is to pass upon a question of fact, which the ECC, the SSS, and the Court of Appeals have used to deny his claim for compensation.  This is not allowed under Section 1 of Rule 45, which states that "[t]he petition shall raise only questions of law which must be distinctly set forth."[21] Hence, questions of fact may not be taken up in a petition for review on certiorari such as this case now before us.  As we have held previously:  

A question of fact exists when the doubt centers on the truth or falsity of the alleged facts while a question of law exists if the doubt centers on what the law is on a certain set of facts. There is a question of fact if the issue requires a review of the evidence presented or requires the re-evaluation of the credibility of witnesses. However, if the issue raised is capable of being resolved without need of reviewing the probative value of the evidence, the question is one of law. xxx

The matter of petitioner’s cigarette smoking, established by two competent government agencies and the appellate court, is thus a matter that cannot be questioned before us via petition for review.  

There is no doubt that petitioner deserves sympathy because even the benefits already given to him were questioned after the SSS found that he was a chronic cigarette smoker.  For humanitarian reasons, as he pursued his claim all the way to the Court as an indigent litigant, and due to his advancing age, we would like to clarify that what had already been given him should no longer be taken away from...
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