Case Digest (G.R. No. 217044) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Rainier Jose M. Yulo and Juliet L. Yulo vs. Bank of the Philippine Islands, G.R. No. 217044, decided January 16, 2019 under the 1987 Constitution, the petitioners received pre-approved credit cards on October 9, 2006. Rainier’s card and an extension card issued to Juliet were used for charging goods and services. Initially, the Spouses Yulo paid their balances but became delinquent by July 2008, with their outstanding indebtedness swelling to ₱264,773.56 by November 29, 2008. On November 11, 2008, BPI sent a demand letter for ₱253,017.62, and on February 12, 2009, another for ₱325,398.42. Thereafter, BPI filed a complaint for sum of money on February 23, 2009 in MTC-Makati (Civil Case No. 97470). The Yulo Spouses admitted card usage but contended their liability was only ₱20,000, asserting nondisclosure of the Terms and Conditions. After failed mediations, MTC Branch 65 rendered judgment on June 29, 2012, holding the Yulos liable for ₱229,378.68 with interest and pena Case Digest (G.R. No. 217044) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Issuance and use of pre-approved credit cards
- On October 9, 2006, BPI issued Rainier a pre-approved credit card; Juliet was given an extension card.
- The Yulo spouses used their cards to charge goods and services and initially paid regularly until July 2008, when they became delinquent and accumulated an outstanding balance of ₱264,773.56 by November 29, 2008.
- Demand letters and filing of complaint
- BPI sent a Demand Letter on November 11, 2008 for ₱253,017.62 and another on February 12, 2009 for ₱325,398.42.
- On February 23, 2009, BPI filed a complaint for sum of money before the Metropolitan Trial Court (MTC) of Makati City; the Yulo spouses admitted card usage but alleged liability of only ₱20,000 and non-disclosure of Terms and Conditions.
- Proceedings in the trial courts and appellate courts
- MTC Branch 65 (June 29, 2012) ruled for BPI: spouses to pay ₱229,378.68 plus 1% interest and 1% penalty per month from February 12, 2009, and ₱15,000 attorneys’ fees.
- RTC Branch 62 (June 26, 2013) dismissed the appeal, holding BPI had proven delivery of the card packet (with T&C) via a signed Delivery Receipt and that the spouses’ use and unsigned charge slips admitted the statements of account.
- CA (February 20, 2015) denied the petition, affirming RTC: Rainier’s authorized representative received the packet, spouses failed to contest monthly statements, and Rainier, experienced in contracts, could not feign ignorance.
- The Yulo spouses filed a Petition for Review on Certiorari to the Supreme Court, contending lack of proof of consent to T&C, invalid agency, excessive charges and improper reckoning period of interest.
Issues:
- Whether BPI proved that Rainier (through his alleged authorized representative) read and consented to the Terms and Conditions governing the pre-approved credit cards.
- Whether the Yulo spouses are bound by the finance charges, penalties and attorney’s fees imposed under the unproven Terms and Conditions, and if the reckoning period for interest was correctly computed.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)