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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.

AT A GLANCE:

A question of law arises when there is doubt as to what the law is on a certain state of undisputed facts. A question of fact is one that requires Courts to review the truthfulness or falsity of the allegations of the parties.

In Viloria v. Heirs of Gaetos, G.R. No. 206240, May 12, 2021, citing the case of Republic of the Philippines v. Malabanan, the Supreme Court distinguished a question of law from a question of fact. The Court held that a question of law arises when there is doubt as to what the law is on a certain state of undisputed facts, while there is a question of fact when the doubt arises as to the truth or falsity of the alleged facts.

Question of Law

A question of law arises when there is doubt as to what the law is on a certain state of undisputed facts. (Viloria v. Heirs of Gaetos)

In Beltran v. Land Bank of the Philippines, G.R. No. 243507, September 29, 2025, there is a question of law when the petitioner is merely asking the court to determine whether the law was properly applied on the given facts and evidence without probing into or reviewing the evidence on record.

There is a question of law if the issue raised is capable of being resolved without the need of reviewing the probative value of the evidence. The resolution of the issue must rest solely on what the law provides on the given set of circumstances. (Century Savings Bank v. Spouses Danilo T. Samonte and Rosalindo M. Samonte, G.R. No. 176212, October 20, 2010)

Question of Fact

On the other hand, in Viloria v. Heirs of Gaetos, the Supreme Court held that a question of fact is one that requires Courts to review the truthfulness or falsity of the allegations of the parties. This review includes assessment of the probative value of the evidence presented. There is also a question of fact when the issue presented is the correctness of the lower court’s appreciation of the evidence presented by the parties. 

It is not the Supreme Court’s function to analyze or weigh all over again evidence already considered in the proceedings at the lower courts. The Supreme Court’s jurisdiction is limited to reviewing only errors of law that may have been committed by the lower court. As it is, the resolution of factual issues is the function of the lower courts, whose findings on these matters are received with respect. (Viloria v. Heirs of Gaetos)

In Century Savings Bank v. Spouses Samonte, it has been held by the Supreme Court that once it is clear that the issue invites a review of the evidence presented, the question posed is one of fact. If the query requires a re-evaluation of the credibility of witnesses, or the existence or relevance of surrounding circumstances and their relation to each other, the issue in that query is factual. 

Exceptions allowing the review of questions of fact by the Supreme Court

However, the Supreme Court may take exceptions when: 

(1) the conclusion is grounded on speculations, surmises, or conjectures; 

(2) the inference is manifestly mistaken, absurd, or impossible; 

(3) there is grave abuse of discretion; 

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

(5) the findings of fact are conflicting; 

(6) there is no citation of specific evidence on which the factual findings are based; 

(7) the findings of absence of fact are contradicted by the presence of evidence on record; 

(8) the findings of theCA are contrary to those of the trial court; 

(9) the CA manifestly overlooked certain relevant and undisputed facts that, if properly considered, would justify a different conclusion; 

(10) the findings of the CA are beyond the issues of the case; and 

(11) such findings are contrary to the admissions of both parties. 

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Alburo Alburo and Associates Law Offices specializes in business law and labor law consulting. For inquiries regarding legal services, you may reach us at info@alburolaw.com, or dial us at (02)7745-4391/ 09175772207/ 09778050020.

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