G.R. No. 127997 - Villanueva vs. Court of Appeals

In 1991, private respondent Almario Go Manuel initiated a civil action for a sum of money with damages before the Regional Trial Court of Cebu City, Branch 8.
The action involved a check dated June 30, 1991 in the amount of P167,600.00, issued by petitioner Felix Villanueva in favor of Almario Go Manuel.
The check was purported to represent payment of loans previously obtained by Villanueva from Go Manuel, which were used as capital for a mining and fertilizer business.
When the check was presented for payment, it was dishonored due to insufficient funds; a subsequent demand for payment was made, which Villanueva did not meet.

Following the dishonor of the check, private respondent concurrently filed a criminal complaint for violation of Batas Pambansa Bilang 22 and the civil complaint for sum of money.
Petitioner contended that his principal obligation amounted only to P23,420.00, disputing the P167,600.00 claim.
On July 27, 1992, the trial court rendered a decision in favor of private respondent, directing petitioner to pay the full amount of P167,600.00. The decision also dismissed the case against co-defendant Melchora Villanueva and imposed costs on the petitioner.
Dissatisfied with the trial court’s ruling, both parties appealed to the Court of Appeals.

The Court of Appeals largely affirmed the trial court’s decision but with modifications:

It directed petitioner to additionally pay attorney’s fees and litigation expenses amounting to 10% of P167,600.00.
It ordered that the entire obligation earn interest at 6% per annum from the filing of the complaint.

On appeal to the Supreme Court, the petitioner reiterated his arguments, asserting that:

The interest rates of 5% and 10% imposed by the lower courts were unenforceable due to the absence of any written stipulation.
His liability should be limited to the amount of P23,420.00 rather than the full P167,600.00.
The Central Bank and the Monetary Board lacked the authority to repeal the usury law.

The lower courts based their decisions on presented evidence regarding the check, the underlying transaction, the subsequent dishonor, and the non-fulfillment of the demand.
The petitioner’s claims, including the variance in the principal obligation and interest stipulations, were challenged by both the trial court and the Court of Appeals.
The appellate courts’ reviews were limited to alleged errors of law rather than a reexamination of the evidentiary record, which was deemed conclusive.

Whether the imposition of interest rates at 5% and 10% for different components of the obligation was enforceable given that there was no written stipulation providing for such rates.

Whether petitioner’s claim that his principal obligation amounted only to P23,420.00 has any merit compared to the full amount of P167,600.00 as determined by the lower courts.

Whether the Court of Appeals erred in its approach regarding the authority of the Central Bank and the Monetary Board to repeal or modify the usury law applicable to the case.

Whether the Supreme Court should reexamine the findings of fact made by the trial and appellate courts, given the limits of its review to errors of law.