Case Digest (G.R. No. 249660)
Facts:
Toyota Shaw, Inc. v. Carolina Valdecanas and Department of Trade and Industry, G.R. Nos. 249660 and 249714, October 06, 2021, Supreme Court Second Division, Inting, J., writing for the Court. The petitions for review on certiorari consolidated two Rule 45 petitions assail the Court of Appeals (CA) Decision of March 27, 2019 (CA-G.R. SP No. 157257) and its October 2, 2019 Resolution denying reconsideration.Carolina Valdecanas (Carolina) purchased a new Toyota RAV4 from Toyota Shaw, Inc. (TSI) for P1,246,000.00, paying a downpayment and financing the balance. The vehicle was delivered on July 25, 2016. Beginning August 24, 2016, Carolina reported a persistent rattling sound and intermittent seatbelt indicator malfunction; from August to October 2016 the vehicle underwent four repair attempts by TSI and a fifth attempt by Toyota Motor Philippines (TMP) without resolving the complaints. On October 29, 2016, after the fifth attempt failed, Carolina served a Notice of Intention to Invoke Lemon Law Rights under Republic Act No. 10642 and later filed a complaint invoking RA 10642 and the Consumer Act (RA 7394).
The Department of Trade and Industry (DTI) Fair Trade Enforcement Bureau (FTEB) rendered a Decision on December 9, 2016 ordering TSI to refund P1,246,000.00 and pay an administrative fine of P240,000.00, finding the vehicle imperfect and that remedies under RA 7394 were available despite Carolina’s incomplete RA 10642 documentary submissions. On May 28, 2018, the DTI affirmed the FTEB decision. TSI filed a certiorari petition with the CA.
On March 27, 2019, the CA partly granted TSI’s petition: it affirmed the DTI decision but deleted the P240,000.00 administrative fine and remanded the case to the DTI to compute the refund amount, holding that the refund should include bank interest from Carolina’s loan; the CA also found TS...(Subscriber-Only)
Issues:
- Was TSI denied procedural due process by the DTI/FTEB such that the DTI acted in excess of jurisdiction or with grave abuse of discretion?
- Did Carolina prove that the subject vehicle was a defective product such that she is entitled to rescission/refund and related remedies under RA 7394 (and related consumer laws)?
- Did the Court of Appeals err in deleting the administrative fine imposed by the DTI under Ar...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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