Facts:

The case involves Roberto Otero as the petitioner and Roger Tan as the respondent. The events leading to the case began when Tan filed a complaint for collection of a sum of money and damages against Otero on July 28, 2005, in the Municipal Trial Court in Cities (MTCC) of Cagayan de Oro City. Tan alleged that Otero had purchased petroleum products on credit from his Petron outlet in Valencia City, Bukidnon, amounting to P270,818.01 between February 2000 and May 2001. Despite several verbal demands for payment, Otero failed to settle his debt.

Otero was served with summons and a copy of the complaint through his wife on August 31, 2005, but he did not file an answer. Consequently, on November 18, 2005, Tan moved to declare Otero in default due to his failure to respond. Otero opposed this motion, claiming he had not received the summons or complaint. A series of hearings were scheduled, but Otero failed to appear, leading the MTCC to declare him in default on April 26, 2006...

Facts:

Background of the Case
Roberto Otero (Otero) was sued by Roger Tan (Tan) for the collection of a sum of money and damages. Tan alleged that Otero purchased petroleum products on credit from his Petron outlet in Valencia City, Bukidnon, from February 2000 to May 2001, amounting to P270,818.01. Despite repeated demands, Otero failed to settle his obligation.

Procedural History

1. Complaint and Default Declaration: Tan filed a complaint on July 28, 2005, with the Municipal Trial Court in Cities (MTCC), Cagayan de Oro City. Otero failed to file an answer despite being served summons through his wife. The MTCC declared Otero in default on May 9, 2006, and allowed Tan to present evidence ex parte.
2. Trial Court Decisions:
   • MTCC Decision (February 14, 2007): Ordered Otero to pay P270,818.01, attorney’s fees of P15,000.00, and litigation expenses of P3,350.00.
   • RTC Decision (December 28, 2007): Affirmed the MTCC decision, noting that Otero was given due process as his wife received the summons and complaint.
3. Appeal to the Court of Appeals (CA): Otero appealed, arguing that the statements of account were inadmissible because they were not authenticated. The CA denied his petition on April 29, 2011, holding that Otero waived his defenses by defaulting.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Default Judgment and Appellate Rights: A defendant declared in default loses the right to present evidence but may still appeal on limited grounds, such as the plaintiff’s failure to prove the material allegations of the complaint.
2. Authentication of Private Documents: Private documents, like the statements of account, must be authenticated before they can be admitted into evidence. Tan’s failure to authenticate the documents rendered them inadmissible.
3. Preponderance of Evidence: In civil cases, the plaintiff must prove the allegations by a preponderance of evidence. Despite the inadmissibility of the statements of account, Tan’s testimonial evidence sufficiently established Otero’s liability.