Case Summary (G.R. No. 176949)
Factual Antecedents
Respondent Lourdes K. Mendoza filed a complaint against petitioner Asian Construction for nonpayment of P1,206,177.00 for fabricated steel materials and supplies sold and delivered from August 7, 1997 to March 4, 1998. Respondent claimed petitioner failed and refused to pay despite demands, prompting respondent to engage counsel. Petitioner moved for a bill of particulars due to absence of attached purchase orders and invoices but was denied. Petitioner filed an answer denying liability and alleging lack of cause of action. Respondent presented testimonies of her salesman and general manager confirming deliveries, while petitioner’s presentation of evidence was deemed waived due to non-appearance.
RTC Decision
The RTC rendered judgment favoring respondent, ordering petitioner to pay P1,206,177.00 as principal, interest of P244,288.59 plus additional 12% per annum until full payment, attorney’s fees of P150,000.00, and costs of suit.
Court of Appeals Ruling
The CA affirmed the RTC decision with modification, ruling that the 1% monthly interest computation should begin 30 days from each delivery date. Petitioner’s motion for reconsideration was denied.
Issues Presented
- Whether the charge invoices are actionable documents.
- Whether delivery of the supplies and materials was duly proven.
- Whether respondent is entitled to attorney’s fees.
Petitioner’s Arguments
- Charge or sales invoices are not actionable documents; failure to deny their genuineness under oath does not admit them.
- The invoices were improperly authenticated and therefore not sufficient evidence.
- The CA erred in affirming attorney’s fees absent an express basis in the RTC decision.
Respondent’s Arguments
- The petition is a rehash of arguments already addressed by the CA and should be dismissed.
- Charge invoices are actionable documents properly identified and authenticated through witness testimony.
- The award of attorney’s fees was justified based on established trial facts.
Legal Analysis: Actionable Documents under Rule 8, Section 7
Documents are actionable only if the cause of action or defense is grounded on such written instruments. The charge invoices here are evidentiary details of the transactions, not the basis of the cause of action. Therefore, they are not actionable documents requiring attachment to the complaint.
Proof of Delivery and Authentication of Invoices
Despite the non-actionable nature of the charge invoices, together with purchase orders, these sufficiently demonstrate petitioner’s orders and acceptance of delivery. Witness Tejero properly identified and authenticated the invoices, testifying that the invoices were stamped received by petitioner’s employee at delivery. Given that civil cases require only a preponderance of evidence, and petitioner failed to present substantial contrary evidence beyond bare denial, the factual findings favor respondent.
Award of Attorney’s Fees
The award of attorney’s fees cannot stand because the RTC decision did not state the factual or legal basis for such award except in the dispositive portion, which is insufficient. The Supreme Court requires the rationale to be clearly stated in the decision to uphold an award of attorney’s fees.
Final Disposition
The petition is partly granted. The Court affirms the decisions
...continue readingCase Syllabus (G.R. No. 176949)
Background and Procedural History
- On January 6, 2000, Lourdes K. Mendoza, sole proprietor of Highett Steel Fabricators (Highett), filed a Complaint for a sum of money before the Regional Trial Court (RTC) of Caloocan City, Branch 126, against Asian Construction and Development Corporation (petitioner), a domestic corporation.
- The complaint alleged that from August 7, 1997, to March 4, 1998, petitioner purchased fabricated steel materials and supplies amounting to ₱1,206,177.00, excluding interests, but failed to pay despite demand.
- Due to non-payment, respondent engaged counsel to pursue her claim.
- Petitioner moved for a bill of particulars, citing absence of copies of purchase orders and invoices attached to the complaint, but this motion was denied by the RTC on March 1, 2000.
- Petitioner filed an Answer with Counterclaim, denying liability and asserting lack of cause of action.
- Respondent presented testimonies of Artemio Tejero (salesman of Highett) and Arvin Cheng (General Manager of Highett) to prove delivery and transaction.
- Petitioner’s presentation of evidence was deemed waived due to repeated non-appearance by petitioner and counsel.
RTC Decision
- On December 1, 2000, the RTC rendered judgment in favor of respondent ordering petitioner to pay:
- Principal sum of ₱1,206,177.00 for the purchase price of materials and supplies delivered;
- Accrued interest of ₱244,288.59 as of August 31, 1999, with additional interest computed at 12% per annum until full payment;
- Attorney’s fees amounting to ₱150,000.00; and
- Cost of suit.
Court of Appeals Decision and Resolution
- On appeal, the Court of Appeals (CA) affirmed the RTC Decision with modification that the 1% monthly interest computation shall start 30 days from the date of each delivery.
- Petitioner’s motion for reconsideration was denied by the CA.
- The petition to the Supreme Court followed, assailing the CA decision and resolution.
Issues Presented
- Whether the charge invoices are actionable documents.
- Whether delivery of the alleged materials was properly proven.
- Whether respondent is entitled to attorney’s fees.
Petitioner’s Arguments
- Charge or sales invoices are not actionable documents; thus, failure to d