Case Digest (G.R. No. 199539) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Sioland Development Corporation v. Fair Distribution Center Corporation, the respondent, Fair Distribution Center Corporation (respondent), supplied Universal Food Corporation products to petitioner Sioland Development Corporation (petitioner) on various occasions in November and December 2007, as evidenced by sales and charge invoices. When P800,894.27 remained unpaid, respondent sent a demand letter dated September 8, 2008, and then filed a collection complaint before the Regional Trial Court (RTC) of San Pablo City, Branch 29. Petitioner received summons on September 29, 2008, and sought three successive extensions to file its Answer, citing heavy workload and voluminous documents. The RTC granted two extensions as “inextendible” until November 8, 2008, but petitioner belatedly filed its Answer with Counterclaim only on November 19, 2008. Respondent moved for default, which the RTC granted on January 8, 2009, and thereafter conducted an ex parte presentation of testimonial Case Digest (G.R. No. 199539) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Transactions
- Sioland Development Corporation (petitioner) purchased various Universal Food Corporation products from Fair Distribution Center Corporation (respondent) during November–December 2007, as shown by charge and sales invoices.
- Total unpaid balance amounted to ₱800,894.27.
- Pre-trial and Default Proceedings
- On September 8, 2008, respondent sent a demand letter for payment of ₱800,894.27; when petitioner did not pay, respondent filed a Complaint for Collection of Sum of Money before the RTC of San Pablo City, Branch 29.
- Summons was served September 29, 2008. Petitioner filed a Formal Entry of Appearance October 14, 2008 and two motions for extension of time (granted until November 8, 2008), but failed to file an Answer until November 19, 2008—beyond the unextendible period.
- Trial Court Decision
- Respondent moved to declare petitioner in default; RTC granted the motion on January 8, 2009, and scheduled ex parte evidence reception on January 30, 2009.
- Respondent presented charge and sales invoices, invoice transmittals, counter receipts, a demand letter, and three witnesses to establish petitioner’s debt.
- RTC Decision (April 14, 2009) held petitioner liable for ₱800,894.27 with legal interest from demand date, awarded ₱80,000 attorney’s fees and costs; Motion for New Trial was denied October 6, 2009. Petitioner appealed to the Court of Appeals (CA).
- Court of Appeals and Supreme Court Proceedings
- CA (May 31, 2011) set aside RTC Decision for failing to state facts and law, then rendered its own judgment ordering payment of ₱800,894.27 plus interest from demand date. Petitioner’s motion for reconsideration was denied November 24, 2011.
- Petitioner filed a Rule 45 petition before the Supreme Court, challenging (a) the denial of its motions, (b) RC and CA compliance with Sec. 14, Art. VIII, and (c) the CA’s refusal to remand for reception of petitioner’s evidence.
Issues:
- Whether the declaration of default against petitioner was proper.
- Whether remand of the case to the trial court for reception of petitioner’s evidence was necessary.
- Whether the CA decision complied with Section 14, Article VIII of the Constitution and Section 1, Rule 36 of the Rules of Civil Procedure.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)