Practice question
In a civil Rule 45 petition, the RTC and CA make directly contradictory findings on a material fact. The petitioner identifies the conflict in the record and asks the Court to consider the recognized exception. Which is consistent with Planters Development Bank?
- Every factual disagreement guarantees reversal
- Conflicting RTC and CA findings can support exceptional factual review, but the exception must be established and does not itself decide the merits
- No factual review is ever legally possible
- Simply writing exception requires the Court to accept every alleged fact
- Every factual issue becomes a separate original case
Legal references
- https://lawphil.net/courts/rules/rc_1-71_civil.html — Rule 45 sections 1–6, verified petition, legal questions, fifteen-day period, qualified thirty-day extension and discretionary review.
- https://lawphil.net/judjuris/juri2005/sep2005/gr_141524_2005.html — Neypes v. Court of Appeals, G.R. No. 141524, September 14, 2005, fresh-period principle applied to Rule 45.
- https://lawphil.net/judjuris/juri2025/jan2025/gr_252841_2025.html — Planters Development Bank v. Heirs of Nilo P. Delos Santos, G.R. No. 252841, January 15, 2025, main decision on the general legal-question rule and conflicting RTC and CA findings as an exception.
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