G.R. No. 182779 - Lazaro vs. Brewmaster International, Inc.

Petitioner: Victorina (Victoria) Alice Lazaro, who is also the co-defendant with her husband.
Respondent: Brewmaster International, Inc., a marketing company engaged in the sale and distribution of beer and other products of Asia Brewery, Inc.

On November 9, 2005, Brewmaster International, Inc. filed a Complaint for Sum of Money at the Metropolitan Trial Court (MeTC) of Makati City.
The Complaint alleges that during the period from February 2002 to May 2002:

The defendants (Petitioner and her husband) obtained beer and other products on credit totaling Php138,502.92.
This transaction was evidenced by photocopied sales invoices (Annexes “A” and “A-1” to “A-11”) which detailed the quantity and cost of the products.

The Complaint further states that despite repeated demands—with demand letters dated April 21, 2003; May 12, 2003; August 5, 2003; and August 17, 2005—the defendants failed to pay the stated amount.
Under the terms of the sales invoices, the defendants had consented that in the event of litigation, the proper venue would be the courts of Makati City and that overdue accounts would bear an interest of 24%.

Prescillo G. Lazaro, one of the respondents to the complaint, filed an answer with counterclaim:

Denied any knowledge of the alleged obligation.
Asserted that he and petitioner had been living separately since January 15, 2002 and that he never authorized any purchase.
Pointed out that the sales invoices indicated “Total” as the purchaser, suggesting that the proper party to sue would have been Total.

Denied transacting with the respondent.
Contended that the documents attached to the Complaint showed that Total was the entity that purchased the goods.

On June 14, 2006, during the scheduled preliminary conference, petitioner and her co-defendant did not appear.
As a result, the MeTC declared the case submitted for decision.
On August 22, 2006, the MeTC dismissed the Complaint:

The court ruled that the respondent had not met the burden of proving that petitioner (or her husband) was liable for the claimed amount.
It emphasized that the sales invoices revealed that the goods were sold to Total and received by a third party, Daniel Limuco, rather than by the petitioner.

Respondent elevated the case to the Regional Trial Court (RTC) through a notice of appeal and submitted additional evidence:

The additional evidence purported that petitioner and her husband, operating as franchisees of a Total gasoline station and convenience store, were involved in the transaction.
The RTC, however, found that admitting the additional evidence would violate the basic rule of fair play and due process.

Respondent filed a petition for review with the CA, invoking Section 7 in conjunction with Section 6 of the Revised Rules of Summary Procedure.
The CA ruled in favor of the respondent:

Asserted that judgment was warranted based solely on the allegations stated in the Complaint, particularly given the nonappearance of the defendants at the preliminary conference.
Held that evidentiary attachments (i.e., the sales invoices) were not to be given undue weight during the early stage of proceedings.

The CA reversed the RTC decision and ordered petitioner and her husband to pay the claimed sum plus interest, specifically:

Php138,502.92 as the principal sum.
Interest at 6% per annum from the filing of the Complaint until finality and at 12% per annum thereafter.
Costs of suit.

Petitioner argued that the CA erred in its interpretation of Section 6 of the Revised Rules of Summary Procedure by:

Automatically granting relief based on the Complaint despite the absence of a bona fide cause of action.
Relying on the nonappearance of the defendants without properly considering the evidentiary sales invoices.

She contended that the Complaint should be scrutinized to determine if it adequately stated a cause of action.
Petitioner maintained that because the sales invoices indicated that Total was the purchaser, no contractual relationship existed between her and the respondent.
The argument further emphasized that, if the Complaint did not specifically charge an actionable transaction involving petitioner, then no relief should be accorded.

Whether the Court of Appeals correctly applied Section 6 of the Revised Rules of Summary Procedure by basing the judgment solely on the allegations in the Complaint, particularly due to the nonappearance of the defendants at the preliminary conference.
Whether the Complaint sufficiently stated a cause of action against petitioner despite the evidentiary documents (sales invoices) indicating that the goods were sold to Total and received by a third party.
Whether the respondent’s additional evidence, submitted at the RTC level and involving facts linking petitioner to the transaction, should have altered the conclusion reached by the lower court.
Whether the automatic granting of relief under Section 6, as interpreted by the CA, contravenes the requirement for a concise and direct statement of the ultimate facts constituting a cause of action.