Case Digest (G.R. No. 224567)
Facts:
The case involves the spouses Fernando and Ma. Elena Santos as petitioners, and Lolita Alcazar, represented by her attorney-in-fact Delfin Chua, as the respondent. On February 2001, Alcazar, who operated the Legazpi Color Center, filed a Complaint for sum of money against the petitioners, claiming that they owed her P1,456,000.00 for paint and construction materials. The complaint was based on a document entitled “Acknowledgment,” allegedly signed by Fernando Santos on December 12, 2000, which recognized his obligation to pay the specified amount. In the Complaint, it was documented that despite written demands for payment, the petitioners failed to remit any payment to Alcazar.
The venue for the case was the Regional Trial Court in Legazpi City, designated as Civil Case No. 9954. In their Answer, the petitioners refuted allegations, asserting that the executed document did not reflect the true contract or intention of the parties and requested a reformation of the actionable d
Case Digest (G.R. No. 224567)
Facts:
- Parties and Transaction Background
- Petitioner-spouses Fernando T. Santos and Ma. Elena Santos were sued by respondent Lolita Alcazar, proprietor of Legazpi Color Center, represented by her attorney-in-fact Delfin Chua.
- The dispute centered on an alleged debt arising from transactions involving the purchase of paint and construction materials amounting to ₱1,456,000.00, which remained unpaid despite prior written demand.
- The Acknowledgment Document
- Respondent’s cause of action was primarily based on an “Acknowledgment” document, which appeared to have been executed by Fernando T. Santos.
- The document stated the debtor’s obligation, including a provision for payment of interest at a rate of 3% per month on the unpaid principal, and was used as evidence to prove the existence and extent of the indebtedness.
- Petitioners contended that the said instrument did not accurately reflect their agreement and that it required reformation; they also argued that only Fernando’s signature appeared, thus questioning its binding effect on Ma. Elena Santos.
- Litigation History in the Trial Court
- In February 2001, respondent filed a Complaint in Civil Case No. 9954 at Branch 5 of the Regional Trial Court of Legazpi City to collect the alleged debt.
- During the proceedings, various evidentiary issues arose, including:
- Presentation of the acknowledgment as possibly a photocopy rather than the original.
- Absence of corroborative receipts, invoices, or statements of account to independently verify the transactions.
- A pre-trial conference was held on September 26, 2005 outlining the matters to be tried and setting the schedule for hearings.
- The respondent presented her evidence (including the acknowledgment) on November 8, 2005, and formally rested her case on November 21, 2005.
- Petitioners attempted to challenge the evidence through a Demurrer to Evidence filed on January 17, 2006 and subsequently moved to reset a scheduled hearing on March 20, 2006; their counsel’s nonappearance at that hearing led the trial court to declare a waiver of their right to present evidence.
- Trial Court Decision and Post-Trial Developments
- On June 27, 2006, the trial court rendered a decision ordering petitioners to pay:
- The sum of ₱1,456,000.00 plus legal interest from the filing of the complaint.
- Litigation expenses and attorney’s fees, while dismissing the counterclaim presented by petitioners.
- Petitioners filed a Motion for Reconsideration arguing several points including:
- That the acknowledgment was not the original and thus should be inadmissible under the best evidence rule.
- That the actual transactions were not adequately evidenced through receipts or statements.
- That the trial court exceeded its authority by effectively precluding their chance to present evidence.
- The trial court denied their Motion for Reconsideration on August 8, 2006.
- Appeal to the Court of Appeals (CA)
- Petitioners subsequently appealed to the Court of Appeals in CA-G.R. CV No. 87935.
- The CA held that:
- Petitioners’ answer amounted to a categorical admission of indebtedness.
- The acknowledgment was sufficiently authenticated and properly offered in evidence, rendering the presentation of additional receipts or statements unnecessary.
- Petitioners had waived their right to oppose the evidence by failing to specifically deny under oath the genuineness and due execution of the acknowledgment.
- Later, in their May 23, 2008 resolution, the CA reaffirmed its position, though it modified the liability of Ma. Elena Santos to ₱600,000.00, consistent with the evidence that she had not signed the acknowledgment.
- Issues Raised on Certiorari
- Petitioners contended that the CA improperly disregarded:
- Their argument that the presentation of a photocopy in lieu of the original violated the best evidence rule.
- Claims of irregularities in the pre-trial conference (lack of proper records) and non-notification of certain hearings.
- The procedural handling of the March 20, 2006 hearing which they argued denied them their day in court.
- They also argued that the admissions in their Answer should not bind Ma. Elena Santos to the full amount, given she did not sign the acknowledgment.
Issues:
- Evidentiary and Procedural Issues
- Whether the presentation of a photocopy of the acknowledgment, instead of the original document, violated the best evidence rule and affected the outcome of the case.
- Whether the trial court and the Court of Appeals were correct in holding that the acknowledgment’s genuineness and due execution were “deemed admitted” because petitioners failed to specifically deny them under oath.
- Impact on Due Process and the Right to Present Evidence
- Whether petitioners were deprived of their right to due process by being declared to have waived their opportunity to present evidence due to nonappearance in scheduled hearings.
- Whether the trial court properly exercised its discretion in handling the motions to reset the hearing and in enforcing strict schedules despite petitioners’ requests for continuance.
- Scope of Admission and Boundaries of Liability
- Whether the admissions contained in petitioners’ Answer should bind both Fernando and Ma. Elena Santos to the full amount of ₱1,456,000.00, or if the liability of Ma. Elena should be limited due to her lack of signature on the acknowledgment.
- Consistency in Evidentiary Requirements
- Whether the change in the CA’s stance—from previously requiring receipts and statements of account to now dismissing such requirements due to the admissions in the Answer—constituted an irregularity or a justified application of procedural rules.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)