Facts:
Lourdes Suites (Crown Hotel Management Corporation) (petitioner) operated a hotel in
Makati City and executed two
contracts with
Noemi Binarao (respondent) for room accommodations of student groups. One contract covered the
AQ College of Nursing & Health Sciences Students, with room-stay periods running from
twenty-seven March 2011 to sixteen April 2011 and from
May 2011 schedules through twenty-one May 2011, involving
twelve rooms and a total contract price of
P1,501,920.00; the other contract covered the
Mariano Marcos State University College of Nursing & Health Sciences Students, with staggered stay dates from
twenty-seven March 2011 through
eleven June 2011 for some batches and from
thirteen June 2011 to twenty-eight May 2011 and similar subsequent periods for additional groups, involving
sixteen rooms and a total contract price of
P2,760,090.00. The total contract price was
P4,262,010.00. Petitioner alleged that respondent paid the total contract price but still had an
unpaid balance of P47,810.00, representing
damages to furniture, a
lost key, and
excess guests; thus, on
twenty-five July 2011, petitioner sent a
demand letter for the unsettled amount. Respondent did not pay, prompting petitioner to file a
Statement of Claim for collection of sum of money plus damages before the
Metropolitan Trial Court of Makati (MeTC). In her Response, respondent asserted that she was not obliged to pay because petitioner
billed the charges twice. Petitioner attacked the form of respondent’s Response as not being in the
Answer form required by
Section 1, Rule 11 of the Revised Rules of Court. The MeTC found that petitioner failed to prove by
preponderance of evidence the existence of the claimed obligation and that respondent, by contrast, confirmed she requested petitioner to make a proper accounting showing the actual number of students who stayed and the number of rooms actually used; it also found that respondent’s payment had already covered the monetary obligation and even resulted in
overpayment of P43,060.00. The MeTC therefore dismissed petitioner’s complaint
with prejudice for lack of cause of action and ordered, as part of the disposition, petitioner to pay respondent
P43,060.00 for refund of overpayment and
P10,000.00 as moral damages, while denying exemplary damages for lack of proof of wanton, fraudulent, reckless, oppressive, or malevolent conduct. Petitioner then filed a petition for
certiorari before the
Regional Trial Court of Makati (RTC), assailing the MeTC’s dismissal and arguing, among others, that dismissal for “lack of cause of action” could not be treated as a dismissal
with prejudice under the rules and that the MeTC improperly relied on evidence rather than on the allegations. In its
Decision dated 7 September 2012, the RTC denied the petition, held that there was
no grave abuse of discretion by the MeTC, and affirmed the MeTC’s ruling. Petitioner’s motion for reconsideration was denied on
16 November 2012, leading to the present
petition for review under Rule 45.
Issues:
Whether the RTC committed reversible error in affirming the MeTC’s dismissal of petitioner’s small-claims complaint
with prejudice for
lack of cause of action, on the ground that petitioner failed to prove its claim by preponderance of evidence.
Ruling:
Ratio:
Doctrine: