Case Digest (G.R. No. 226495)
Facts:
Spouses Dennis and Cherrylyn "Cherry" Garcia, doing business under the name and style of Ecolamp Multi-Resources v. Northern Islands, Co., Inc., G.R. No. 226495, February 05, 2020, the Supreme Court Second Division, Inting, J., writing for the Court. The Court reviewed a Rule 45 Petition for Review on Certiorari challenging the Court of Appeals' Decision (Nov. 26, 2015) and Amended Decision (Aug. 17, 2016) in CA-G.R. CV No. 98237 that reversed the Regional Trial Court (RTC), Branch 215, Quezon City's dismissal of Northern Islands' complaint for sum of money.Northern Islands, Co., Inc. (respondent) is a seller of 3D household appliances that designated Ecolamp Multi-Resources (petitioner Spouses Garcia as proprietors) its exclusive distributor in Southern Mindanao. Between March and July 2004, respondent alleges Ecolamp ordered goods totalling P8,040,825.17 which were shipped and delivered to Ecolamp in Davao City via Sulpicio Lines and Starlite Cargo, but remained unpaid. Northern filed a complaint for sum of money, sought a writ of preliminary attachment, and demanded payment (demand dated May 4, 2005). The RTC granted the application for preliminary attachment (Oct. 13, 2005) and sheriff levied on six real properties registered in Dennis's name (writ acted on Nov. 7, 2005).
At trial Northern introduced delivery cargo receipts, bills of lading, proforma bills of lading, and testimony from its finance and warehouse personnel and shipping officers to establish deliveries to Ecolamp and the identity of the recipient (one Alvin who signed various receipts). Northern explained the missing sales invoices and other internal documents by testimony that those records were taken by a stockholder who assumed operations. Cherrylyn Garcia was the sole witness for Ecolamp; she denied receipt of deliveries for March–July 2004, asserted that a pink sales invoice (issued pre-payment) was not issued for those months (thus no transaction), and claimed transactions occurred in October 2004 and were settled.
The RTC, in a Decision dated September 21, 2011, dismissed Northern's complaint, holding that packing lists, picking lists, delivery receipts and bills of lading could be given significance only upon proof of the corresponding purchase orders and sales invoices; because Northern failed to prove existence and loss of those documents, secondary evidence rules could not be invoked. Northern appealed.
The Court of Appeals reversed in its November 26, 2015 Decision (CA-G.R. CV No. 98237), ordering the Garcias to pay P5,200,900.00 with interest; after motions for reconsideration, the CA issued an ...(Pro-only)
Issues:
- In a Rule 45 petition, may the Supreme Court review and re-evaluate the lower courts' factual findings in this case?
- Did Northern Islands prove, by preponderance of evidence, the deliveries and resulting indebtedness of Ecolamp for which the Garcias were properly held liable for P6,...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)