Title
Supreme Court
David Nacionales vs. Hon. Leah Garnet G. Solde-Annogui and Pera-Multipurpose Cooperative, represented by Jay Bonghanoy
Case
G.R. No. 249080
Decision Date
Sep 15, 2021
Petitioner defaulted on a loan, contested repayment terms and due process in small claims court; Supreme Court dismissed petition for bypassing lower courts and lack of jurisdictional errors.

Case Summary (G.R. No. 249080)

Case Background

The case began when PERA-Multipurpose Cooperative granted Nacionales a loan of P67,700.00 on July 13, 2017, with a repayment period of 24 months at an interest rate of 24% per annum. Nacionales defaulted on the payment and, as of March 29, 2019, owed P49,436.46, which included interest, penalties, and attorney's fees. Following an unheeded demand for payment from the Cooperative, a small claims action was initiated to recover the owed amount and filing fees.

Procedural Developments

Despite being properly summoned and notified of the claims, Nacionales did not respond to the court, resulting in both parties appearing before the court on July 3, 2019. On that date, a hearing was held, and the court issued a decision partly granting the Cooperative's claims, ordering Nacionales to pay P36,647.00 in principal and P7,447.00 in interest.

Petitioner's Claims and Arguments

Nacionales filed a petition for certiorari and mandamus, alleging various grievances against the decision rendered by Judge Solde-Annogui. He argued that the repayment schedule violated the Truth in Lending Act and contended that the computation of interest constituted a fraudulent scheme. Additionally, Nacionales claimed that he was denied due process, asserting that the Judge was not present during the hearing and that his due process rights were violated due to her absence.

Respondents’ Responses

In her comment, Judge Solde-Annogui maintained that the computation did not render the loan agreement void, asserting that the terms of the loan were clear and understood by Nacionales. She denied claims of denying due process, stating that she was present during the proceedings and proceeded with the case after Nacionales allegedly left the hearing. The Cooperative echoed these points, emphasizing the procedural missteps made by Nacionales in filing his petition directly with the Supreme Court without going through the Regional Trial Court (RTC).

Legal Considerations and Court Findings

The petition was dismissed primarily due to a violation of the hierarchy of courts, as per Section 24 of the Revised Rules of Procedure for Small Claims Cases, which states that decisions from MCTCs are final and non-appealable. While the policy allows for petitions for certior

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