Facts:

The case at bar involves a petition for review on certiorari filed by Crisostomo Alcaraz (petitioner) against the Court of Appeals and Equitable Credit Card Network, Inc. (respondents). The events leading to this case date back to May 1995, when Equitable issued a credit card, specifically the Equitable Visa Gold International Card, to the petitioner. The card came with both peso and dollar accounts, enabling Alcaraz to make purchases and obtain cash advances from affiliated merchants and ATMs. Over time, Alcaraz accumulated significant unpaid debts, totaling $8,970.54 on his dollar account and P192,500.00 on his peso account by February 1999. Despite receiving several demand letters from Equitable, Alcaraz failed to settle these obligations.

In response, Equitable filed a complaint in the Regional Trial Court of Makati City for the collection of his unpaid balance, claiming accrued interest rates and penalties as per the "Terms and Conditions Governing the Issuance and Use

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Facts:

Background and Credit Card Issuance

• In May 1995, private respondent Equitable Credit Card Network, Inc.—a company engaged in extending credit accommodations through credit cards—issued the Equitable Visa Gold International Card to petitioner Crisostomo Alcaraz.
• The card, with specified card and account base numbers, allowed the petitioner access to both peso and dollar accounts for cash advances at ATMs and for the purchase of goods and services at accredited merchant establishments.

Accumulation of Obligations and Demand for Payment

• Petitioner, by making use of the credit card, accumulated an outstanding balance through cash advances and purchases on credit.
• Despite receiving several demand letters from Equitable, the petitioner failed to settle his unpaid obligations.
• Equitable’s complaint before the lower court sought the payment of the accumulated balance along with:
• Interest rates of 2.5% per month on the peso account and 1.5% per month on the dollar account.
• Late penalties/surcharges as specified in the “Terms and Conditions Governing the Issuance and Use of Equitable Visa Card.”
• Liquidated damages and attorney’s fees at specified rates based on the Terms and Conditions.

Petitioner’s Contentions

• The petitioner admitted using the credit card but contended that he was issued the card as an “honorary member,” which exempted him from submitting an application, signing any document, or being bound to the stipulated interest-bearing installment scheme.
• He claimed that, as an honorary member, he should be allowed to pay in installments free of any interest.
• Petitioner further asserted that he had requested a reconciliation of his accounts from Equitable without receiving any satisfactory response, thus rendering the collection action premature.

Proceedings in Lower Courts

• At the trial court level:
• After several postponements of the pretrial conference—allegedly due to both the petitioner’s actions and circumstances such as inclement weather—the court, upon Equitable’s motion, declared the petitioner in default.
• The trial court allowed Equitable to present its evidence ex parte, which included testimony from its collection officer and documentary evidence.
• The trial court ruled in favor of Equitable but rejected the claim for liquidated and exemplary damages.
• Petitioner’s Motion for New Trial was filed and subsequently denied.
• On appeal:
• The Court of Appeals partially affirmed the trial court’s decision.
• The appellate court modified the judgment by ordering payment of:
• P81,000.00 on the peso account.

ii. US$4,397.34 (or its peso equivalent) on the dollar account, with an imposed 12% annual interest rate from designated dates.

Allegations of Due Process Violation and Bias

• Petitioner raised two principal issues on appeal:
• Alleging a violation of his right to due process because the trial court allowed Equitable to present its evidence ex parte due to the failure to postpone the pretrial conference despite his wife’s representation that he had suffered a stroke.
• Claiming that the monetary award was not in keeping with the evidence as well as applicable law and jurisprudence.
• The petitioner further charged the trial court with arbitrariness and bias, alleging that the repeated resetting of the pretrial conference and certain conduct of the court personnel and judge demonstrated prejudice against him.

Issue:

Whether the trial court violated the petitioner’s right to due process by allowing Equitable to present its evidence ex parte without postponing the pretrial conference in view of the petitioner’s alleged medical condition and his counsel’s health issues.

• The petitioner argued that his and his counsel’s absence, justified by their respective medical problems, should have merited a postponement.
• He maintained that the trial court’s decision to proceed, and declare him in default, evidenced judicial bias and partiality.

Whether the monetary award ordered by the lower courts—including the application of interest, late fees, and other charges under the Terms and Conditions—is consistent with the evidence, applicable law, and jurisprudence.

• The petitioner contested the application of the interest rates and other charges stipulated in the “Terms and Conditions” on the basis that he never signed or accepted such terms as he was granted “honorary membership.”
• He argued there existed a significant disparity between the accumulated credit and the amount demanded by Equitable.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)