Case Digest (G.R. No. 167330) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Ramon Villuga and Mercedita Villuga v. Kelly Hardware and Construction Supply, Inc., G.R. No. 176570, decided July 18, 2012 by the Supreme Court Third Division under the 1987 Constitution, petitioners filed on March 3, 1995 in the Regional Trial Court of Bacoor, Cavite (Branch 89) a Complaint for a Sum of Money and Damages against respondent for alleged unpaid purchases of construction materials amounting to P259,809.50 from November 19, 1992 to January 5, 1993, plus 14% interest, attorney’s fees and litigation expenses. In their Answer they admitted the purchases but asserted partial payments of P110,301.80 and P20,000.00 and offered to pay the principal in installments without interest. Respondent obtained leave to file an Amended Complaint on January 30, 1996 and a Second Amended Complaint on January 24, 1997 to refine the period covered and confirm only P20,000.00 was paid, served on March 8, 1996 a Request for Admission, to which petitioners filed belated Comment Case Digest (G.R. No. 167330) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Complaint
- On March 3, 1995, Kelly Hardware and Construction Supply Inc. (respondent) sued Spouses Ramon and Mercedita Villuga (petitioners) before the RTC of Bacoor, Cavite for P259,809.50 alleged unpaid purchases of construction materials plus interests, attorney’s fees, litigation expenses, and costs.
- Respondent alleged purchases between November 19, 1992 and January 5, 1993 and demands for payment ignored by petitioners.
- Early Pleadings and Offers
- In their Answer, petitioners admitted purchases but disputed the exact amount, claimed partial payments of P110,301.80 (March 4, 1994) and P20,000.00 (August 9, 1994), and offered to pay the balance upon verification.
- Petitioners’ July 18, 1995 Manifestation offered to pay P259,809.50 in installments without interests and costs; respondent agreed to principal but insisted on interests and fees.
- Amendments and Discovery
- Respondent filed an Amended Complaint (Jan. 30, 1996) raising total purchases to P279,809.50 and balance P259,809.50. Petitioners repeated their partial-payment defense.
- Respondent’s Request for Admission (March 8, 1996) asked petitioners to admit documents and the P279,809.50 obligation less P20,000.00; petitioners filed belated Comments.
- Second Amended Complaint and Summary Judgment Motion
- On January 24, 1997, respondent filed a Second Amended Complaint alleging purchases from July 29, 1992 to August 10, 1994 and partial payment of P110,301.80 applied to other debts, leaving P259,809.50. Petitioners answered, again claiming partial payment.
- On September 4, 1997, respondent moved to expunge petitioners’ Comments on the Request for Admission and for summary judgment, arguing deemed admission and absence of material issues.
- RTC and Appellate Proceedings
- The RTC, in its September 28, 1998 Order, granted the motion, expunged the Comments, and rendered summary judgment ordering petitioners to pay P259,809.50 with legal interest. A May 6, 1999 Motion for Reconsideration was denied.
- The CA, in its November 30, 2006 Decision and February 8, 2007 Resolution, affirmed the RTC Orders. Petitioners petitioned the Supreme Court under Rule 45.
Issues:
- Whether petitioners’ Comments on the Request for Admission were improperly expunged and deemed admissions because of belated filing and waiver by amendment of the complaint.
- Whether the RTC erred in granting summary judgment when petitioners raised genuine issues of fact, particularly concerning partial payments.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)