Case Digest (G.R. No. 198998)
Facts:
Young Builders Corporation v. Benson Industries, Inc., G.R. No. 198998, June 19, 2019, the Supreme Court Second Division, Caguioa, J., penned the Resolution. Petitioner is Young Builders Corporation (YBC) and respondent is Benson Industries, Inc. (BII).In August 1998 YBC sued BII in the Regional Trial Court (RTC), Cebu City, for collection of P24,832,352.38 allegedly due for work performed on BII’s commercial building. YBC alleged a main contract (initially P36.9M for a five‑storey building, later revised) and extra works, and attached an Accomplishment Billing dated May 18, 1998 as Annex A to show amounts accomplished and unpaid. BII answered, admitting the contract but denying an accomplishment‑billing basis, alleging delay, abandonment, defective workmanship, and that payments already made exceeded any collectible balance; BII specifically denied portions of the complaint under oath.
At trial YBC presented one witness (architect Nelson Go Yu) and documentary exhibits including the Accomplishment Billing (Exhibit B), cost proposals (Exhibits A, C), a certification by BII’s president (Exhibit E), and a letter by Ernesto Dacay, Sr. (Exhibit F). BII filed demurrers to evidence (denied by the RTC) and later presented five witnesses. On November 21, 2008 the RTC rendered judgment for YBC ordering BII to pay the claimed amount with interest, attorney’s fees and litigation expenses.
BII appealed to the Court of Appeals (CA). The CA (Twentieth and Nineteenth Divisions; decision penned by Associate Justice Edgardo L. Delos Santos) reversed: it excluded the Accomplishment Billing for lack of authentication and found YBC failed to substantiate claimed accomplishments with receipts, payrolls or comparable proof; consequently it dismissed the complaint. The CA also found the Ernesto letter unauthenticated and treated the Mary Dacay certification (Exhibit E) as a photocopy inadmissible under the Best Evidence Rule. The CA denied YBC’s motion for reconsideration in a September 14, 2011 Resolution.
YBC filed a petition under Rule 45 for review on certiorari to the Supreme Court assailing the CA’s evidentiary rulings, arguing (among others) that the Accomplishment Billing was deemed admitted because it was attached to the complaint and not specifically denied under oath, and that BII had even offered it as its Exhibit 2. BII filed a c...(Pro-only)
Issues:
- As a procedural matter, may the Court review conflicting findings of fact between the RTC and the CA in a Rule 45 petition?
- Whether the CA erred in excluding and refusing to give probative value to YBC’s Accomplishment Billing (Exhibit B) on the ground that it was not specifically denied under oath and/or not authenticated.
- Whether the CA erred in excluding or discounting other documentary evidence (Ernesto Letter, Exhibit F; Mary Certification, Exhibit E) and i...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)