G.R. No. 150905 - Citibank vs. Teodoro

Petitioner Citibank, N.A. operates a Mastercard credit card system; on December 14, 1990, respondent Efren S. Teodoro applied for and was issued Citibank Mastercard No. 5423-3920-4457-7009.
The card terms required payment of all charges within 30 days; unpaid balances incur 3.5% monthly interest plus a 5% monthly penalty fee.
By January 20, 1995, petitioner claimed respondent’s total obligations—including interest and service charges—to be ₱191,693.25.

On January 25, 1996, petitioner filed a collection complaint before the RTC of Makati (Civil Case No. 96-092), which was dismissed for lack of jurisdiction and then raffled to MTC Branch 66 as Civil Case No. 51586.
At trial, petitioner offered photocopies of sales invoices/charge slips (Exhibits “F” to “F-4”) totaling ₱24,388.36, bearing respondent’s signature, to prove his purchases.
The MTC, in its July 25, 2000 Decision, found the photocopies sufficient proof, ordered respondent to pay ₱24,388.36 plus 3.5% interest and 5% penalty monthly, and awarded 25% attorney’s fees.
The RTC, on October 30, 2000, affirmed the MTC decision; the CA, on July 31, 2001, reversed and set aside the trial courts’ rulings for insufficiency of evidence, denying petitioner’s motion for reconsideration on November 22, 2001.

Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, contesting the CA’s reversal of the trial courts.
The Supreme Court deemed the case submitted for decision on September 16, 2002.

Did the Court of Appeals err in reversing and setting aside the trial courts’ decisions for insufficiency of evidence?
Did the Court of Appeals err in holding that petitioner failed to prove (a) due execution, and (b) loss or unavailability of the original charge slips (Exhibits “F” to “F-4”) under Sections 3 and 5 of Rule 130 of the Rules of Court?