Case Digest (G.R. No. 183034)
Facts:
- The case involves Spouses Fernando and Ma. Elena Santos as petitioners and Lolita Alcazar, represented by Delfin Chua, as the respondent.
- In February 2001, Alcazar, owner of Legazpi Color Center (LCC), filed a complaint against the Santos couple for a sum of money.
- The complaint, assigned Civil Case No. 9954 to Branch 5 of the Regional Trial Court of Legazpi City, sought to recover P1,456,000.00 for unpaid paint and construction materials.
- Alcazar's claim was based on an acknowledgment document signed by Fernando Santos, indicating an obligation to pay the specified amount, executed on December 12, 2000, with a provision for 3% monthly interest.
- The Santos couple denied the allegations, claiming the document did not reflect the true agreement and asserting the actual amount owed was only P600,000.00.
- They argued that the acknowledgment was improperly executed and sought to reform the document.
- The trial court held a pre-trial conference and set hearing dates, but the Santos couple failed to appear multiple times, leading to a waiver of their right to present evidence.
- On June 27, 2006, the trial court ruled in favor of Alcazar, ordering the Santos couple to pay the full amount claimed, plus interest and attorney's fees.
- The Santos couple's motion for reconsideration was denied, and their appeal to the Court of Appeals (CA) was unsuccessful, resulting in the current petition for review on certiorari.
Issue:
- (Unlock)
Ruling:
- The Court ruled that the genuineness and due execution of the acknowledgment were deemed admitted due to the Santos couple's failure to specifically deny them under oath.
- The Court affirmed the CA's decision that the acknowledgment was sufficient to establish the Santos couple's liability without needing additional receipts or statements of account.
- The Court held that the...(Unlock)
Ratio:
- The Supreme Court emphasized that under Philippine law, the genuineness and due execution of a document are deemed admitted unless specifically denied under oath by the opposing party.
- The Santos couple's failure to properly deny the acknowledgment in their answer resulted in its a...continue reading
Case Digest (G.R. No. 183034)
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. The events leading to the case began in February 2001 when Alcazar, the proprietor of Legazpi Color Center (LCC), filed a complaint for a sum of money against the Santos couple. The complaint, which was assigned Civil Case No. 9954 to Branch 5 of the Regional Trial Court of Legazpi City, sought to recover P1,456,000.00 for unpaid paint and construction materials obtained by the Santos couple from LCC. The basis of Alcazar's claim was an acknowledgment document signed by Fernando Santos, which stated his obligation to pay the specified amount. The acknowledgment was executed on December 12, 2000, and included a provision for 3% monthly interest on the unpaid principal.
In their answer, the Santos couple denied the allegations, asserting that the document did not reflect the true agreement and that the actual amount owed was only P600,000.00. They also claimed that the acknowledgment was not properly executed and sought to reform the document. The trial court conducted a pre-trial conference and set various hearing dates for the presentation of evidence. However, the Santos couple failed to appear on several occasions, leading the trial court to declare that they had waived their right to present evidence. On June 27, 2006, the trial court ruled in favor of Alcazar, ordering the Santos couple to pay the full amount claimed, along with interest and attorney's fees.
The Santos couple subsequently filed a motion for reconsideration, which was denied. They then appealed to the Court of Appeals (CA), wh...