Facts:

Bankard, Inc. (now RCBC Bankard Services Corporation), the petitioner in this case, is a duly constituted domestic corporation that operates as a credit card provider, extending credit accommodations to its cardholders for the purchase of goods and services from accredited establishments. The respondent, Luz P. Alarte, applied for and received a credit card, specifically the Bankard myDream JCB Card No. 3562-8688-5155-1006. In 2007, Bankard filed a collection case against Alarte in the Metropolitan Trial Court (MeTC) of Pasig City, specifically Civil Case No. 13956, after alleging that Alarte had availed herself of credit accommodations totaling P67,944.82 as of July 9, 2006, which included unbilled monthly installments, charges, and penalties. Following a written demand for payment, Alarte failed to settle her obligations.

Despite having been served with summons, Alarte did not file an answer, prompting Bankard to file a Motion to Render Judgment. On July 15, 2009, the MeTC dis

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Facts:

Background of the Parties

• Petitioner Bankard, Inc. (currently RCBC Bankard Services Corporation) is a domestic corporation engaged in the business of extending credit accommodations through its credit card facilities.
• Respondent Luz P. Alarte was the credit card holder who availed herself of the petitioner’s services by applying for and being granted credit accommodations under the Bankard myDream JCB Card.

Initiation of the Collection Case

• In 2007, Bankard, Inc. filed a collection case against respondent before the Metropolitan Trial Court (MeTC) of Pasig City, docketed as Civil Case No. 13956, Branch 72.
• The complaint alleged that:
• Respondent had utilized the credit card to make purchases at various accredited business establishments.
• Based on a July 9, 2006 Statement of Account, respondent’s credit availments totaled P67,944.82, which included unbilled monthly installments, interest, and penalty charges.
• Respondent failed or refused to settle the outstanding balance despite receiving written demand.

Proceedings in the Lower Courts

• Metropolitan Trial Court
• After respondent failed to answer the summons, petitioner filed a Motion to Render Judgment.
• On July 15, 2009, the MeTC rendered its decision dismissing the complaint for lack of preponderance of evidence. Specifically, the court noted that the single statement of account did not indicate actual purchase transactions by the respondent.
• Regional Trial Court
• Petitioner appealed the MeTC decision.
• On May 6, 2010, the RTC affirmed the MeTC’s dismissal, emphasizing that the statement of account only showed charges (late charges and interest) without detailing actual credit transactions, thereby failing to prove that the alleged debt was incurred through the use of the credit facility.
• The RTC also held that the disputable presumption under Rule 131, Section 3(q) did not suffice to prove the creditor’s claim without a clear demonstration of transactions.
• Court of Appeals
• Petitioner filed a Petition for Review before the CA (docketed as CA-G.R. SP No. 114345).
• On September 28, 2011, the CA affirmed the decisions of the MeTC and RTC, reasoning that the statement of account lacked detailed information evidencing actual purchases and was therefore insufficient to support petitioner’s claim.
• Petitioner subsequently moved for reconsideration, but the CA, in its July 4, 2012 Resolution, maintained its position dismissing the petition.

Petitioner’s Arguments and Subsequent Developments

• Petitioner contended that:
• The July 9, 2006 Statement of Account accurately reflected respondent’s obligation and contained a waiver provision.
• Respondent’s failure to answer the complaint, as well as her failure to file any comments or positions in the subsequent appellate proceedings, should estop her from denying the validity of the statement of account.
• A reversal of the lower court decisions was necessary to prevent injustice and potential unjust enrichment on the part of the respondent.
• Notably, the petitioner acknowledged that its complaint might not have been optimally prepared, leaving room for the argument that further evidentiary clarification was required.

Issue:

Sufficiency of the Evidence

• Whether the single Statement of Account, which merely recorded a running balance with late charges and interest, was sufficient to prove that respondent had actually incurred purchases through the use of the petitioner’s credit card.
• Whether the lack of detailed transactional data in the statement undermined the petitioner’s claim by failing to meet the required burden of proof by preponderance of evidence.

Implications of Respondent’s Non-Participation

• Whether respondent’s failure to answer the summons in the MeTC, and her non-participation in subsequent appellate proceedings (including the RTC appeal and CA petition for review), could be regarded as an admission of the alleged charges or as estopping her from contesting the statement of account.
• Whether such non-response could shift the evidentiary balance in favor of petitioner despite the insufficiency of detailed supporting documents.

Interpretation and Role of the Statement of Account

• How the running balance, as indicated in the statement, should be interpreted in terms of its evidentiary value in credit card transactions.
• The issue of whether a statement that consolidates principal, finance, and penalty charges without itemizing individual purchase transactions can serve as conclusive evidence of a contractual obligation.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)