G.R. No. L-28349 - Calo vs. Enage

Ruel Martinez served as Operations Manager of Multi-International Business Data System, Inc. from late 1990 until January 22, 1999.
On June 4, 1994, Martinez obtained a car loan of ₱648,288.00 payable via monthly deductions from bonuses or commissions; agreement provided that upon termination any unpaid balance becomes immediately due and demandable.

November 11, 1998: petitioner informed Martinez of an outstanding loan balance of ₱418,012.78 and itemized prior deductions.
November 24, 1998: Martinez requested a breakdown of his benefits, indicating intention to offset his loan.
January 22, 1999: petitioner terminated Martinez for cause, demanded payment of ₱418,012.78 and surrender of the vehicle within three days.
Martinez failed to pay; June 23, 1999: petitioner reiterated demand; still unpaid.
July 12, 1999: petitioner filed complaint in RTC Makati Branch 148 for payment of ₱418,012.78 plus interest, exemplary damages, attorney’s fees and costs.
August 28, 1999: Martinez answered, claiming full payment via salary, bonus and commission deductions; presented a September 10, 1996 certification of ₱337,650.00 payments.

November 22, 2002 RTC Decision: ruled for petitioner; ordered Martinez to pay ₱418,012.78 plus 12% interest from June 23, 1999, exemplary damages of ₱10,000, attorney’s fees of ₱20,000, costs; dismissed counterclaims.
October 18, 2006 CA Decision: reversed RTC; found Martinez had discharged his obligation based on (a) September 10, 1996 certification, (b) salary deductions, and (c) admission of ₱230,275.22 in payments; dismissed complaint.
Multi-International Business Data System, Inc. filed petition under Rule 45 with the Supreme Court challenging CA’s findings on payment and document admissibility.

Whether respondent Martinez fully discharged his car-loan obligation to petitioner.
Whether the September 10, 1996 certification is admissible to prove payment of the loan.