G.R. No. 249080 - David Nacionales vs. Hon. Leah Garnet G. Solde-Annogui and Pera-Multipurpose Cooperative, represented by Jay Bonghanoy

Case Digest (G.R. No. 249080)
Expanded Legal Reasoning Model

Facts:

Overview of the Case

This is a petition for certiorari and mandamus with prayer for damages filed under Rule 65 of the Rules of Court.
The petition was filed by petitioner David Nacionales against the decision rendered by the 3rd Municipal Circuit Trial Court (MCTC) of Nabunturan, located in Nabunturan, Compostela Valley (now Davao de Oro).
The case originated from a small claims action filed by PERA Multipurpose Cooperative, represented by Jay C. Bonghanoy, seeking the collection of a sum of money along with damages.

Transaction and Underlying Dispute

On July 13, 2017, PERA Multipurpose Cooperative granted a loan to petitioner Nacionales amounting to P67,700.00.
The loan was to be repaid within 24 months, with an agreed interest rate of 24% per annum computed on a straight basis.
Petitioner defaulted in payment, and as of March 29, 2019, his total outstanding obligation—including interest, penalty, and attorney’s fees—amounted to P49,436.46.
A demand letter was issued by the cooperative for the payment of the debt, but the petitioner neglected to act upon it.
Consequently, PERA Multipurpose Cooperative filed the small claims action demanding:

Payment of the outstanding amount of P49,436.46, and
Reimbursement of the P2,715.00 filing fee.

Proceedings in the Lower Court

Despite having received summons and a statement of claim, petitioner Nacionales failed to file any response.
On July 3, 2019, both parties appeared in court; however, they were unable to reach a settlement.
The 3rd MCTC proceeded with the hearing, submitted the case for decision, and partly granted the cooperative’s claim.
The court’s decision ordered petitioner Nacionales to pay:

A principal amount of P36,647.00 to the cooperative;
Interest amounting to P7,447.00, plus an additional interest rate of 24% per annum from the finality of the decision until full payment; and
The costs of the suit.

Contentions Raised by the Petitioner

Petitioner Nacionales argued that the computation in the repayment schedule amounted to a violation of the Truth in Lending Act.
He claimed that the deduction of a prepaid interest of P16,248.00 from the original loan amount of P67,700.00 was fraudulent, effectively reducing the principal to P51,452.00.
Based on the alleged fraud, he contended that the officers of the cooperative should be held liable for syndicated estafa.
Petitioner also asserted that he was denied due process, alleging that on July 3, 2019:

Judge Solde-Annogui was absent from the trial court;
No proper hearing was held as only the Clerk of Court attended to the parties based on an alleged authorization by the judge; and
He was surprised to later receive the court’s decision.

Additionally, he questioned the imposition of the 24% per annum interest on the total amount awarded to the cooperative.

Responses and Judicial Commentary

In her comment and response, Judge Solde-Annogui maintained:

An error in the computation of interest does not nullify the contract.
The petitioner was fully aware of and understood the terms and conditions of the loan and promissory note.
There was no evidence of a fraudulent scheme such as mistake, violence, intimidation, undue influence, or fraud in the signing of the promissory note.

She refuted the due process claim by explaining that:

She was present on the day of the hearing, waited for the parties in her chambers, and proceeded with the case after the petitioner’s non-appearance.
The petitioner’s failure to abide by proper court protocol (i.e., his refusal to enter the chambers) contributed to the procedural developments of the case.

The respondent further argued, emphasizing:

The proper venue for filing extraordinary writs and petitions pursuant to the hierarchy of courts is the Regional Trial Court (RTC) rather than the Supreme Court.
There exists a plain, speedy, and adequate remedy at the RTC level for such disputes.

Jurisprudential Context and Policy on Hierarchy of Courts

The petitioner’s direct filing with the Supreme Court violated the established policy on the hierarchy of courts.
Citing precedents such as People v. Cuaresma, the Supreme Court reiterated that petitions for extraordinary writs should be directed to the RTC or the Court of Appeals unless special, important, or compelling reasons justify a direct invocation of the Supreme Court’s jurisdiction.
The hierarchy is intended to streamline judicial processes and reserve the Supreme Court’s docket for matters truly within its exclusive jurisdiction.

Issues:

Violation of the Truth in Lending Act

Whether the computation in the repayment schedule of the cooperative—specifically the deduction of prepaid interest from the loan amount—violates the Truth in Lending Act and thereby renders the transaction fraudulent.

Alleged Denial of Due Process

Whether the petitioner was denied his constitutional right to due process by the conduct of the trial court, notably alleging that a proper hearing was not conducted due to the non-appearance of Judge Solde-Annogui on the day of the hearing.

Legality of the Imposed Interest Rate

Whether the imposition of a 24% per annum interest rate on the awarded sum after finality of judgment is legally justifiable.

Compliance with the Judicial Hierarchy

Whether the petitioner’s direct filing of a certiorari and mandamus petition with the Supreme Court—circumventing the RTC—is a valid exercise given the established hierarchy of courts and the proper forum for such petitions.

Ruling:

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Ratio:

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Doctrine:

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Case Digest (G.R. No. 249080) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 249080) Expanded Legal Reasoning Model

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Case Digest (G.R. No. 249080)
Core Legal Reasoning Model

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Case Digest (G.R. No. 249080)
Expanded Legal Reasoning Model