Title
Spouses Yulo vs. Bank of the Philippine Islands
Case
G.R. No. 217044
Decision Date
Jan 16, 2019
BPI issued credit cards to the Yulos, who accumulated debt. Courts ruled BPI failed to prove consent to terms, but Yulos are liable for principal with legal interest, voiding penalties and fees.

Case Digest (G.R. No. 217044)
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)

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