G.R. No. 143721 - Villaluz vs. Ligon

Petitioner Teresita E. Villaluz and respondent Rolando R. Ligon were engaged in several business ventures.
In 1987, Villaluz borrowed money from Ligon, with the loan secured by postdated checks amounting to P1,543,586.00, which later bounced due to insufficient funds or a closed account.

Amid pending criminal cases for violation of Batas Pambansa Blg. 22, Villaluz and Ligon agreed to settle the controversy through a Memorandum of Agreement.
Key terms of the agreement included:

Recognition of an original indebtedness of P3,489,252.00 (inclusive of interests), with Villaluz having already paid P165,000.00.
A condonation of P1,324,252.00, reducing the purported obligation to P2,000,000.00.
The issuance of a check by Villaluz for P1,900,000.00 (after further payment of P100,000.00), with the promise that failure to pay by December 31, 1990, would automatically reinstate the condoned amount back into the debt.
A stipulation that, upon payment of the agreed amount, Ligon would facilitate the dismissal of the criminal cases against Villaluz.

Villaluz’s check for P1,900,000.00, issued on December 31, 1990, bounced upon presentment.
Ligon repeatedly demanded payment through letters dated March 5, 1991, and July 1, 1991, but Villaluz failed to comply.

On April 2, 1992, Ligon filed a civil complaint with the RTC of Makati, Branch 134, seeking the recovery of P3,224,252.00 plus legal interest and attorney’s fees.
Villaluz’s failure to appear at pre-trial conferences led to a declaration of default, after which the court received Ligon’s evidence ex-parte.
Subsequent proceedings included:

Filing of a Motion for New Trial and a Motion to Admit Answer by Villaluz on November 23, 1992, both of which were granted.
Villaluz’s Answer, wherein she claimed illiteracy, alleged instances of deceptive practices regarding the delivery of imported goods in exchange for checks, and maintaining that the checks had no valid consideration.
Numerous postponements and scheduling resets of hearings from 1995 to early 1996, largely attributable to the absence of Villaluz and her counsel.
Finally, on March 11, 1996, after persistent delays and failure to appear, the trial court ruled the case submitted for decision.

On May 7, 1996, the RTC rendered a decision ordering Villaluz to pay the stipulated sum along with attorney’s fees and costs.
Villaluz filed a motion for reconsideration (May 23, 1996), which was denied on July 22, 1996.
The Court of Appeals (CA) affirmed the RTC’s decision in a ruling dated October 1, 1999, and subsequently denied Villaluz’s motion for reconsideration in a resolution dated June 6, 2000.

Forum shopping was committed by Ligon by pursuing multiple cases for similar reliefs.
Her fundamental right to due process was violated because she was deprived of a fair opportunity to present evidence.
The trial court erred in refusing to consider her “Sinumpaang Salaysay” affidavit, which she argued should have demonstrated that the memorandum and the check were void for lack of valid consideration.

Petitioner argued that the same parties, subject matter, and reliefs in different courts pointed to litis pendentia and, therefore, forum shopping, citing prior jurisprudence.
It was contended that the prohibition against forum shopping predated administrative circulars, and that the remedy should have been invoked earlier.

Whether or not the petitioner was deprived of her fundamental right to due process.

Villaluz maintained that the repeated postponements and her inability to present evidence constituted a denial of her right to be heard.
She argued that the trial court should have been more accommodating given the circumstances surrounding the need for an accounting and the parties’ settlement efforts.

Whether or not an error was committed in not considering the evidence already on record showing the alleged lack of valid consideration in the Memorandum of Agreement and the associated checks.

Petitioner contended that her “Sinumpaang Salaysay,” which detailed her claims of illiteracy and deception, should have been admitted and given evidentiary weight.
Respondent maintained that since the affidavit was not formally offered during trial, it could not be used to impeach or alter the findings based on the available evidence.