Case Summary (G.R. No. 220826)
Loan Transaction and Dishonor of Check
• June 28, 1999: Park loaned Choi ₱1,875,000.00; Choi issued PNB Check No. 0077133 dated August 28, 1999 in that amount.
• October 5, 1999: Park’s deposit attempt returned dishonored for closed account.
• May 11, 2000: Park’s counsel sent demand letter; registry receipt and stipulation confirm Choi’s receipt on May 19, 2000.
• Choi did not cure dishonor or repay the loan.
Criminal Complaint and MeTC Proceedings
• August 31, 2000: City Prosecutor charged Choi under B.P. 22; docketed as Criminal Case No. 294690 before MeTC Branch 65.
• Choi pleaded not guilty, filed demurrer to evidence arguing lack of proof of notice of dishonor.
• February 27, 2003: MeTC granted demurrer and dismissed criminal complaint; motion for reconsideration denied.
First Civil Determinations and Remands
• RTC Branch 60 (Sept 11, 2003): Held civil liability survives despite criminal insufficiency; ordered payment of ₱1,875,000.00 with legal interest.
• RTC Branch 60 on reconsideration: Reversed and remanded to MeTC to allow defense to present civil-aspect evidence.
• CA dismissal on procedural grounds; Supreme Court (Second Division, 2007) denied Park’s petition and remanded for civil evidence reception; final Jan 18, 2008.
Repeated Postponements and Waiver of Defense Right
• July 16, 2008–May 19, 2009: Four postponements at Choi’s instance.
• September 15, 2010: Postponed for interpreter assistance; last warning issued.
• November 23, 2010: Postponed due to interpreter certification issue; warned this was final grant.
• March 7, 2011: Choi’s counsel retired; requested another postponement; MeTC denied motion and declared Choi’s right to present evidence waived.
MeTC Decision on Civil Liability
• April 26, 2011: MeTC found Choi civilly liable for ₱1,875,000.00 (face value of dishonored check) plus 12% interest per annum from August 31, 2000, attorney’s fees of ₱200,000.00, and filing-fee reimbursement of ₱9,322.25; costs against accused.
RTC Branch 142 Ruling and Reconsideration
• December 23, 2011: RTC affirmed MeTC Decision, noting repeated postponements caused waiver of defense evidence; appeal denied.
• March 28, 2012: Denied Choi’s motion for reconsideration filed before his reply period expired; Choi did not file reply; petition under Rule 42 elevated to CA.
Court of Appeals Reversal
• March 30, 2015 CA Decision: Reversed RTC; remanded to MeTC for full hearing to ensure “day in court”; viewed postponements as “justifiable” (interpreter error, counsel substitution) and relaxed procedural strictness to prevent substantial injustice.
• September 30, 2015 CA Resolution: Denied Park’s motion for reconsideration.
Supreme Court Issue and Ruling
Issue
• Whether the CA committed reversible error in remanding the case and depriving enforcement of RTC and MeTC findings.
Ruling
• CA erred. No due process violation: Choi was repeatedly warned and given ample opportunity over nearly three years to present defense evidence; his own motions caused delay and waiver of right to present evidence was properly declared by MeTC and affirmed by RTC.
• Denial of reconsideration by RTC before reply deadline did not breach due process: a reply is limited to issues in opposition, which in turn responds only to reconsideration grounds.
Supreme Court’s Determination of Liability
• Choi admitted in counter-affidavit that he borrowed from Park. His bare allegations of partial payment (₱1,590,000.00) lacked proof; Park’s testimony and documentary evidence established full indebtedness of ₱1,875,000.00.
• Judicial admission binds Choi; burden to prove payment lay on him and was unmet.
• Accordingly, Choi owes Park the full face value of ₱1,875,000.00.
Interest and Ancillary Awards
• Monetary interest requires written stipulation; none exists → no contractual interest.
• Compensatory (legal) interest arises by law for delay: Articl
Case Syllabus (G.R. No. 220826)
Facts of the Case
- On June 28, 1999, Hun Hyung Park (private complainant) loaned ₱1,875,000.00 in cash to Eung Won Choi (accused/respondent).
- In payment, Choi issued Philippine National Bank Check No. 0077133 dated August 28, 1999 for the same amount.
- On October 5, 1999, Park deposited the check, only to have it dishonored due to a closed account.
- Park’s counsel sent an extrajudicial demand letter on May 11, 2000; registry return and stipulation show Choi received it on May 19, 2000.
- Choi failed to settle the dishonored check or repay the loan.
Procedural History
- Park filed a complaint for estafa and violation of B.P. 22; the City Prosecutor filed Information dated August 31, 2000 before the Metropolitan Trial Court of Makati City (MeTC), Criminal Case No. 294690.
- On arraignment (April 16, 2001), Choi pleaded not guilty. After presentation of the prosecution’s evidence, Choi filed and the MeTC granted a demurrer to evidence (Order February 27, 2003), dismissing the criminal complaint.
- Park appealed to the Regional Trial Court (RTC), Branch 60, Makati City. By Decision dated September 11, 2003, RTC-60 held that civil liability survived and ordered Choi to pay ₱1,875,000.00 plus legal interest.
- Upon Choi’s motion for reconsideration, RTC-60 reversed and remanded for reception of civil evidence. Park elevated the remand order to the Court of Appeals (CA), which dismissed his petition on procedural grounds.
- In G.R. No. 165496, the Supreme Court (Second Division) denied Park’s petition on the merits (June 29, 2007 Resolution, final January 18, 2008), and remanded Criminal Case No. 294690 to the MeTC for civil-evidence proceedings.
- At the MeTC, trial on civil evidence was repeatedly postponed—July 16, 2008 (holiday), January 7, 2009, April 7, 2009, May 19, 2009, August 5, 2009 (holiday), September 15, 2010 (interpreter issue), November 23, 2010 (interpreter certification), and March 7, 2011 (new counsel is