Saturday, June 30, 2007 Distinction between questions of law and of fact By Dominador A. Almirante Labor case digest
A COMPLAINT for illegal dismissal and other money claims was filled by petitioner Godofredo Morales against respondent Skills International Co. After unfavorable decisions of the labor arbiter, the National Labor Relations Commission (NLRC) and the Court of Appeals, Morales raised before the Supreme Court the issue of whether Skills International was the one responsible for his deployment abroad to be held liable to his claims. Was the action of Morales well-taken?
The distinction between questions of law and questions of fact is settled. A question of law exists when the doubt or difference centers on what the law is on a certain state of facts. A question of fact exists if the doubt centers on the truth or falsity of the alleged facts. Although the delineation seems simple, determining the true nature and extent of the distinction is sometimes problematic. For example, it is incorrect to presume that all cases where the facts are not in dispute automatically involve purely questions of law.
There is a question of law if the issue raised is capable of being resolved without 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. 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. (Microsoft Corp. versus Mexlcorp Inc., G.R. No. 140946, Sept. 13, 2004, 438 SCRA 224).
In this case, the issues brought for our consideration calls for the re-examination of the evidence presented by the parties and the determination of whether the labor arbiter, the NLRC, and the Court of Appeals erred in their respective evaluation of the same. This we cannot do without blurring the difference between a question of fact and a question of law – a significant distinction as far as the remedy of appeal by certiorari is concerned. (Godofredo Morales vs. Skills International Co., et. al., G.R. No. 149285, Aug. 30, 2006).
