Case Summary (G.R. No. 239092)
Factual Background
BPI issued a credit card to Ram M. Sarda, who allegedly incurred an obligation amounting to ₱1,213,114.19 through credit card transactions. Following non-payment, BPI filed a complaint against Sarda and his spouse for collection of the outstanding debt. The respondents denied receiving the credit card or applying for it, asserting they had not incurred the debt as they did not have physical possession of the card.
Proceedings in the RTC
The Regional Trial Court (RTC) ruled in favor of BPI, finding that Sarda's former employee, Melissa Tandogon, received the credit card on his behalf. The court determined that the evidence presented by BPI, including documentary evidence of billing statements and testimony from BPI account specialists, sufficiently established Sarda's responsibility for the debt. The RTC reduced the requested amounts for attorneys' fees and finance charges but ultimately ruled that the respondents should pay the claimed sums.
Ruling of the Court of Appeals
Dissatisfied with the RTC's decision, the respondents appealed to the Court of Appeals (CA), which reversed the RTC ruling. The CA concluded that BPI failed to prove that Sarda had physical possession of the credit card, that Tandogon was authorized to receive it, and that he had any obligation regarding charges made after a certain date. The CA held that due diligence was not observed by BPI in issuing the card, particularly given evidence suggesting Sarda might not have been receiving billing statements due to an address discrepancy.
Legal Arguments by BPI
BPI argued that the numerous transactions reflected in the statements of account were sufficient to establish liability, asserting that even if the address was incorrect, it retained the right to collect as Sarda had historically made payments. BPI further claimed that as a pre-qualified client, Sarda was nonetheless responsible for the credit card usage, and it had exercised due diligence by ensuring identity checks during transactions.
Defense by Respondents
The respondents contended that BPI's failure to provide clear evidence of their application for and receipt of the credit card negated any liability for the outstanding obligations. They argued that the lack of a formal application for the supplementary card undermined BPI's claims regarding the charges made under that card. They cited BPI’s irregular issuance practices and claimed all transactions from prior years had been settled.
The Court's Analysis
The Supreme Court affirmed the CA’s ruling, underscoring that BPI failed to establish the critical elements necessary for holding the
...continue readingCase Syllabus (G.R. No. 239092)
Case Background
- The case involves an appeal from the April 27, 2018 Decision of the Court of Appeals (CA) in CA-G.R. CV No. 106788, which reversed the April 12, 2016 Decision of the Regional Trial Court (RTC) of Makati City in Civil Case No. 14-351.
- The RTC originally ruled in favor of the petitioner, ordering the respondents to pay the petitioner for credit card purchases, including accumulated amounts, interest, charges, and attorney's fees.
Parties Involved
- Petitioner: Bank of the Philippine Islands (BPI), a domestic commercial bank offering credit card services.
- Respondents: Spouses Ram M. Sarda (Mr. Sarda) and "Jane Doe" Sarda, who denied the existence of the credit card obligation.
Facts of the Case
- On March 28, 2014, BPI filed a complaint against the respondents, claiming that Mr. Sarda had incurred an outstanding obligation of P1,213,114.19 through credit card transactions.
- BPI asserted that Mr. Sarda's last payment was made on March 15, 2013, with subsequent demands for payment being ignored.
- The respondents countered that they had neither applied for nor received the BPI credit card and denied any obligation to pay.
Trial Proceedings
- BPI presented documentary evidence, including a Delivery Receipt, Terms and Conditions of Use of the credit card, and statements of account.
- Respondents refuted BPI's claims through testimony from Mr. Sarda, who insisted they did not possess the credit card.
Ruling of the Regional Trial Court (RTC)
- The RTC ruled in favor of BPI, concluding that Mr. Sarda had likely received the credit card through an employee, Melissa Tandogon.
- The court found that Mr. Sar