Facts:

The case involves BPI Express Card Corporation (BECC) as the petitioner and Eddie C. Olalia as the respondent. The events leading to this case began when Olalia applied for and was granted a credit card by BECC, which issued him Card No. 020100-3-00-0281667 with a credit limit of P5,000. In January 1991, Olalia's card expired, and a renewal card was issued. Concurrently, BECC issued an extension card in the name of Cristina G. Olalia, who is Olalia's ex-wife. BECC claimed that both cards were delivered to Olalia simultaneously, but he denied ever applying for or receiving the extension card.

Subsequently, it was discovered that the extension card was used for purchases amounting to P101,844.54 in Iloilo and Bacolod from March to April 1991. BECC sent a demand letter to Olalia for the unpaid charges, but he contested the liability, asserting that he did not authorize the use of the extension card and that he had not seen his ex-wife since she moved to the United Sta...

Facts:

Background of the Parties

• Petitioner, BPI Express Card Corporation (BECC), operates a credit card system that extends credit to its cardholders for the purchase of goods and services from its member establishments.
• Respondent, Eddie C. Olalia, applied for and was granted membership and credit accommodation with BECC.
• Upon membership, Olalia was issued BECC Card No. 020100-3-00-0281667 with a credit limit of ₱5,000.

Issuance and Renewal of Credit Cards

• In January 1991, Olalia’s card expired, and a renewal card was issued to him.
• Concurrently, an extension card, BECC Card No. 020100-2-01-0281667, was also issued in the name of Cristina G. Olalia, who is identified as Olalia’s ex-spouse.
• BECC alleged that the extension card was delivered and received by Olalia at the same time as the renewal card.
• Olalia firmly denied ever applying for or receiving an extension card in his ex-wife’s name.

Transactions and Disputed Charges

• Charge slips presented in court evidenced that the extension card was used for purchases made from March to April 1991 in the province of Iloilo and the City of Bacolod.
• The total unpaid charges incurred from the use of the extension card amounted to ₱101,844.54.
• BECC sent a demand letter to Olalia demanding payment for the disputed amount.

Proceedings in the Lower Courts

• At the Regional Trial Court, Branch 145 in Makati City, Olalia was held liable for the amount of ₱13,883.27, which represented purchases made under his own credit card.
• A Motion for Reconsideration was later filed by BECC asserting that Olalia should also be held liable for the extension card purchases.
• The Motion for Reconsideration was granted in April 1995, amending the judgment to hold Olalia liable for ₱136,290.97.
• On appeal, the Court of Appeals reversed this amended judgment and sustained a decision holding Olalia liable only for ₱13,883.27, with applicable interest and penalty fees as ordered.

Allegations and Contentions

• BECC based its claim on the Renewal Card Acknowledgement Receipt bearing Olalia’s signature and a stipulation in the card’s terms and conditions, which made the cardholder and his extensions jointly and severally liable for transactions.
• Olalia contended that he neither applied for nor received the extension card, and further maintained that he did not authorize any transactions made using the extension card.

Issue:

Validity of the Extension Card Issuance

• Whether an extension card in the name of Cristina G. Olalia was validly issued under the terms and conditions governing the BECC credit card system.
• Whether the issuance of such a card complied with the requisite procedural requirements, namely the payment of the necessary fee and the submission of an application.

Liability for Transactions Made with the Extension Card

• Whether respondent Eddie C. Olalia can be held liable for the purchases made using the extension card allegedly issued in the name of his ex-wife.
• Whether Olalia’s signature on the Renewal Card Acknowledgement Receipt is sufficient evidence to impute ownership and responsibility for the extension card’s transactions.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)