G.R. No. 220826 - Hun Hyung Park vs. Eung Won Choi

On June 28, 1999, Hun Hyung Park (Park) lent ₱1,875,000.00 to Eung Won Choi (Choi).
Choi issued PNB Check No. 0077133 dated August 28, 1999 in favor of Park, which was dishonored on October 5, 1999 for being drawn on a closed account.

Park sent a demand letter dated May 11, 2000; Choi received it on May 19, 2000.
Park filed estafa and B.P. 22 complaints; on August 31, 2000, Choi was charged under B.P. 22 (Criminal Case No. 294690 MeTC Makati).

Choi pleaded not guilty, then filed a demurrer to evidence for lack of proof of notice of dishonor; the MeTC granted it and dismissed the criminal case on February 27, 2003.
The prosecution’s motion for reconsideration was denied; Park appealed to RTC Branch 60.

RTC Branch 60 Decision (Sept 11, 2003) found insufficient proof of criminal liability but maintained civil liability and ordered Choi to pay ₱1,875,000.00 with interest.
On reconsideration, RTC Branch 60 reversed itself and remanded the case to MeTC for reception of civil evidence (2004).

Park’s petition to the Court of Appeals (CA) was dismissed on procedural grounds; he then appealed to the Supreme Court in G.R. No. 165496, which on June 29, 2007 remanded the case to MeTC for civil evidence.
Before MeTC, Choi sought multiple postponements (July 16, 2008 to March 7, 2011); after six postponements and repeated warnings, MeTC declared waiver of right to present evidence (March 7, 2011).

On April 26, 2011, MeTC found Choi civilly liable for ₱1,875,000.00 plus 12% interest per annum from August 31, 2000 until full payment, ₱200,000.00 attorney’s fees, and ₱9,322.25 filing fees.
Choi appealed to RTC Branch 142.

Decision dated December 23, 2011 affirmed MeTC’s decision in toto.
Order dated March 28, 2012 denied Choi’s motion for reconsideration (filed before expiry of reply period).

CA Decision dated March 30, 2015 reversed RTC Branch 142 and remanded to MeTC for reception of evidence, citing “justifiable reasons” for postponements.
CA Resolution dated September 30, 2015 denied Park’s motion for reconsideration.

Park filed Rule 45 petition before the Supreme Court (G.R. No. 220826), challenging CA’s reversal of RTC Branch 142.
Both parties submitted their comments; the case was set for resolution.

Whether the Court of Appeals erred in reversing the RTC Branch 142 decision and remanding the case for reception of evidence.
Whether Choi was deprived of due process by (a) MeTC’s declaration of waiver of right to present evidence after multiple postponements, and (b) RTC Branch 142’s denial of his motion for reconsideration two days before his reply period expired.
Whether Choi’s civil liability extends to the full face value of ₱1,875,000.00 and the proper computation of interest.