G.R. No. 202573 - Bankard, Inc. vs. Alarte

Petitioner Bankard, Inc. (now RCBC Bankard Services Corporation), a domestic corporation engaged in issuing credit cards and extending credit accommodations to its cardholders.
Respondent Luz P. Alarte, a cardholder under Bankard myDream JCB Card No. 3562-8688-5155-1006.
In 2007, Bankard filed a collection case seeking payment of P67,944.82 allegedly due from respondent, inclusive of unbilled monthly installments, charges, and penalties, based on a Statement of Account dated July 9, 2006.

Petitioner alleged respondent’s use of her credit card to purchase goods and services, then refused to pay despite written demands.
Summons was duly served, but respondent failed to file an answer. Petitioner filed a Motion to Render Judgment.
The MeTC dismissed the complaint, ruling that petitioner failed to prove by preponderance of evidence that respondent incurred the alleged debt as the Statement of Account only showed late charges and interest without details of purchases or transactions. Petitioner thus did not establish the claim’s validity.

Petitioner appealed; the RTC affirmed the MeTC’s dismissal.
RTC held that the Statement of Account proved only that it was sent regularly, but lacked details showing actual use of credit facilities or the imposition of penalties and interest.
The disputed presumption under Rule 131, Section 3(q) of the Rules of Court only covers regular issuance, but not the truth of the amounts claimed.
Petitioner’s request for a clarificatory hearing to prove the principal amount was denied as beyond the scope of such hearings.

Petitioner filed a Petition for Review; CA denied the petition and affirmed RTC and MeTC judgments.
CA reiterated that petitioner bore the burden to prove the claim by preponderance of evidence, which was not met as the Statement of Account lacked specifics of purchases or transactions.
Respondent’s failure to answer did not amount to admission of the debt since the debt itself was not sufficiently proven.

Petitioner argued the Statement of Account was binding and respondent was estopped from denying it.
Petitioner also contended that respondent’s silence amounted to admission of debt.
Petitioner underscored that affirmance of prior judgments would create a precedent allowing credit card holders to evade liability through mere silence.
The Supreme Court acknowledged the nature of the Statement of Account as a running balance reflecting previous unpaid amounts and rising charges, and recognized petitioner’s failure to properly present evidence and clarify its claim.
The Court noted the credit card transaction’s tripartite contractual nature and the need for petitioner to amend the complaint and present supplemental evidence for clarity.

Whether petitioner established its claim for collection against respondent by a preponderance of evidence.
Whether the dismissal of the case by the MeTC, affirmed by the RTC and CA, was proper given the nature and sufficiency of evidence presented by petitioner.
Whether respondent’s failure to file an answer or comment amounted to an admission of petitioner’s claim.
Whether the Court of Appeals erred in denying petitioner’s Motion for Reconsideration.
Whether the case should be remanded for further proceedings to allow petitioner to amend its complaint and present additional evidence.