G.R. No. 236920 - Ridao vs. Handmade Credit and Loans, Inc.

On February 20, 2004, petitioner Gemma A. Ridao obtained a US$4,000.00 loan evidenced by Promissory Note No. 2000029B from respondent Handmade Credit and Loans, Inc., represented by Teofilo Manipon.
On August 24, 2004, two transactions took place:

An additional loan was obtained which purportedly increased her obligation to US$6,167.00, evidenced by the same promissory note and a Statement of Loan Release.
A separate loan of PHP40,000.00 was given, evidenced by another promissory note.

Due to failure to pay on the due dates despite numerous oral demands, Handmade Credit sent a Demand Letter on September 21, 2012 demanding:

Payment of US$6,167.00 plus 4% monthly interest on the dollar loan.
Payment of the PHP40,000.00 obligation with legal interest, along with attorney’s fees.

On July 11, 2013, Handmade Credit filed a Complaint for collection of sum of money with damages before the Regional Trial Court (RTC) of Urdaneta City, Pangasinan, Branch 48.
The Complaint included promissory notes, statements of loan release, and other documents alleging that Ridao had made no payment at all.

In her Answer with Special and Affirmative Defenses and Counterclaim, Ridao admitted to obtaining a loan of US$4,000.00 but:

Claimed that the loan was extended on a personal, familial basis, not as a creditor-debtor transaction.
Asserted receipt of an additional US$300.00, making her total loan obligation US$4,300.00.

Ridao produced as evidence a payment record—a page of a ledger maintained by her late husband Avelino—which showed several payments:

Detailed entries for four payments of US$300.00, US$300.00, US$300.00, and US$200.00.
Irregular entries for purported additional payments (US$800.00, US$900.00, and US$1,500.00) that later became a point of contention.

Ridao denied the existence of the additional transactions (the increased US$6,167.00 obligation and the PHP40,000.00 loan) arguing that:

The promissory notes and related annexes had been materially altered (including tampered dates and erased signatures) without her consent.
She was even abroad at the time some of these transactions allegedly took place, making the additional loan void.

The execution of the personal loan and its modifications (including the change of date on the promissory note).
The receipt of payments by Ridao via Avelino as evidenced in part by the ledger.

The ledger was admitted as evidence, though without specific sworn denial by Handmade Credit.
The 4% monthly interest was condemned as exorbitant and against public policy.
The additional PHP40,000.00 loan was declared void.
It was held that the US$4,300.00 obligation had been fully paid by Ridao.

Partially granted the appeal.
Held that the promissory notes were void due to material alterations, tampering, and superimpositions.
Found that although Ridao admitted to a US$4,300.00 loan, the atypical entries in the ledger (especially for the last three payments) cast doubt on full payment.
Ordered Ridao to pay the remaining unpaid balance of US$3,200.00 (or its peso equivalent) with 6% interest per annum from the date of filing of the complaint.

Ridao filed a Motion for Reconsideration which was denied in a Resolution dated January 11, 2018.

Whether the appellate court erred in ordering Ridao to pay US$3,200.00 (or its peso equivalent) with interest despite her submission of a ledger as evidence of payment.
Whether the ledger, not being an actionable document under Sections 7 and 8, Rule 8 of the Rules of Court, could be deemed as implying admission of payment by Handmade Credit.
Whether the material alterations and tampering with the promissory notes, which were central evidence of the loan transactions, render them void and inapplicable as a source of Ridao’s obligation.