Case Summary (G.R. No. 176949)

Overview of the Case

• The case involves a Petition for Review on Certiorari filed by Asian Construction and Development Corporation against Lourdes K. Mendoza.
• The petition challenges the Decision and Resolution of the Court of Appeals regarding a civil case for a sum of money.
• The primary legal principle established is that in civil cases, the party with the most convincing evidence prevails.

Factual Background

• Lourdes K. Mendoza, as the sole proprietor of Highett Steel Fabricators, filed a complaint against Asian Construction for unpaid purchases of fabricated steel materials.
• The total amount claimed was P1,206,177.00, exclusive of interest, with allegations of non-payment despite demands.
• Asian Construction requested a bill of particulars, which was denied by the Regional Trial Court (RTC), leading to the filing of an Answer with Counterclaim by the petitioner.

Evidence Presented

• Respondent presented testimonies from two witnesses: Artemio Tejero, a salesman, and Arvin Cheng, the General Manager of Highett.
• The petitioner failed to present evidence due to repeated non-appearances, resulting in a waiver of their right to present a defense.

RTC Decision

• The RTC ruled in favor of Mendoza, ordering Asian Construction to pay the principal amount, accrued interest, attorney's fees, and costs of suit.
• The decision included specific amounts for the principal, interest, and attorney's fees.

Court of Appeals Ruling

• The Court of Appeals affirmed the RTC's decision but modified the computation of interest to begin 30 days from the date of each delivery.
• The petitioner’s motion for reconsideration was denied.

Legal Issues Raised

• The petitioner raised three main issues:
  1. Whether charge invoices are actionable documents.
  2. Whether the delivery of materials was duly proven.
  3. Whether the respondent is entitled to attorney's fees.

Petitioner’s Arguments

• The petitioner contended that charge invoices are not actionable documents and that their failure to deny the invoices does not constitute an admission.
• They argued that the invoices were not properly authenticated and that the RTC did not provide a basis for awarding attorney's fees.

Respondent’s Arguments

• The respondent argued that the petitioner’s claims were merely a rehash of previous arguments and that the charge invoices were indeed actionable documents.
• She maintained that the invoices were properly authenticated and that the award of attorney's fees was justified based on the trial evidence.

Ruling on Charge Invoices

• The Supreme Court ruled that charge invoices are not actionable documents as they merely provide details of transactions and are evidentiary in nature.
• The cause of action was based on the contract of sale, not the invoices themselves.

Ruling on Delivery of Materials

• The Court found sufficient evidence to prove that the supplies and materials were delivered to the petitioner.
• Testimony from Tejero confirmed the delivery and the stamp...continue reading

Case Syllabus (G.R. No. 176949)

Case Overview

• This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court, filed by Asian Construction and Development Corporation (petitioner) against Lourdes K. Mendoza (respondent).
• The main legal issue concerns the enforcement of a monetary judgment related to the sale of fabricated steel materials.
• The case was decided by the First Division of the Supreme Court of the Philippines on June 27, 2012.

Factual Antecedents

• On January 6, 2000, Lourdes K. Mendoza, as the sole proprietor of Highett Steel Fabricators, initiated a complaint against Asian Construction and Development Corporation in the Regional Trial Court (RTC) of Caloocan City, Branch 126.
• The complaint, docketed as Civil Case No. C-19100, alleged that between August 7, 1997, and March 4, 1998, the petitioner purchased various fabricated steel materials from Highett amounting to P1,206,177.00, exclusive of interests, and failed to pay despite demands.
• Mendoza claimed that the non-payment forced her to engage legal counsel.
• The petitioner sought a bill of particulars due to the absence of purchase orders and invoices in the complaint, but the RTC denied this motion.
• The petitioner then filed an Answer with Counterclaim, denying liability and asserting a lack of cause of action.
• During the trial, Mendoza presented the testimonies of Artemio Tejero, a salesman, and Arvin Cheng, the General Manager of Highett.
• The evidence for the petitioner was deemed waived due to repeated non-appearances of both the petitioner and its counsel.

Ruling of the Regional Trial Court

• On December 1, 2000, the RTC ruled in favor of respondent Mendoza, ordering the petitioner to pay:
  • P1,206,177.00 as the principal amount for ...continue reading