Case Digest (G.R. No. 201001)
Facts:
MCMP Construction Corp. v. Monark Equipment Corp., G.R. No. 201001, November 10, 2014, Supreme Court Third Division, Velasco Jr., J., writing for the Court.Petitioner MCMP Construction Corporation leased five pieces of heavy equipment from respondent Monark Equipment Corporation under a Rental Equipment Contract in 2000; deliveries were acknowledged by MCMP representatives and supported by invoices and acknowledgment receipts dated December 5, 2000 and January 29, 2001. The invoices contained payment terms: payment within 30 days, interest at 24% per annum, a 1% monthly collection fee compounded monthly, a 2% per month penalty charge for late payment, and a stipulation for attorney’s fees of 25% and venue selection.
MCMP failed to pay the rental fees within 30 days, making only two partial payments of PhP100,000.00 each on April 15 and August 15, 2001. By April 30, 2002, Monark computed MCMP’s indebtedness at PhP1,282,481.83 (principal PhP765,380.33 plus interest, penalties and collection fees). Monark filed suit for sum of money with the Regional Trial Court (RTC), Branch 96, Quezon City (Civil Case No. Q-02-47092) on June 18, 2002.
In its answer, MCMP asserted prematurity and claimed an alleged side agreement limiting charges to actual use time, admitting this side agreement was not in the Contract. At trial Monark’s Senior Account Manager, Reynaldo Peregrino, testified that Monark’s original copy of the Contract had been lost despite diligent efforts to locate it and offered a photocopy; MCMP objected under the Best Evidence Rule and failed to produce its own copy despite a court directive. MCMP’s witnesses, however, admitted delivery of the equipment to MCMP’s project sites.
On November 20, 2007, the RTC rendered judgment for Monark for PhP1,282,481.83, plus 25% attorney’s fees and costs. MCMP moved for reconsideration; Monark sought clarification. On April 28, 2008 the RTC denied MCMP’s motion but granted Monark’s clarification to expressly include the contractual stipulations on interest, penalties, collection fee and attorney’s fees in the dispositive portion and to authorize accrual of charges after April 30, 2002 until full payment.
MCMP appealed to the Court of Appeals (CA), which, in a Decision dated October 14, 2011, affirmed the RTC in toto; the CA denied MCMP’s motion for reconsideration in a Resolution dated March 9, 2012. MCMP then filed a Rule 45 Petition for Review on Certiorari with the Supreme Court on April 20, 2012, pressing pr...(Pro-only)
Issues:
- Under the Best Evidence Rule, should Monark’s presentation of secondary evidence (a photocopy and testimony) of the lost original Contract have been excluded?
- Are the stipulated interest, penalty/collection charges and attorney’s fees imposed by the trial court excessive, unconscionable or otherwise subject...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)