Case Summary (G.R. No. 148786)
Allegations and Initial Complaint
Manzano filed a complaint for recovery of the outstanding balance on April 6, 1990, before the Regional Trial Court of Iriga City, along with a motion for the establishment of a supplier’s lien on the payments due to Despabiladeras from CSPC. The legal basis for the claim included not just the principal amount but also additional claims for damages, attorney's fees, moral damages, and other litigation expenses.
Respondent's Counterclaims
In her answer, Despabiladeras countered the allegations, asserting that Manzano had altered the pricing of materials and claimed to have made additional payments totaling ₱57,069.00. Furthermore, she disputed the amount owed and indicated that previous payments applied to other debts contradict the petitioner’s claims. The trial court's pre-trial conference revealed there was no dispute on material delivery, but disagreement existed over the claimed price.
Procedural Developments
Following the pre-trial, a series of procedural complications arose. Instead of following the trial court's directive for an itemized list of materials, Manzano requested admissions from Despabiladeras regarding material delivery and payment amounts. Despabiladeras did not respond until trial, where she contested certain facts but admitted other deliveries without confirming their specified prices.
Trial Court Findings
The trial court's ruling on July 7, 1997, eventually favored Manzano based on Despabiladeras’s failure to respond under oath to his request for admission, leading to deemed admissions of the delivered goods and the partial payment made. The court highlighted that admissions made in legal proceedings do not require further proof unless shown to be erroneous.
Award of Interests and Damages
Manzano sought an 8% monthly interest on the unpaid balance; however, the trial court found that a verbal agreement for such interest was not legally enforceable since interests must be stipulated in writing according to Article 1956 of the Civil Code of the Philippines. The court awarded him legal interest at 12% per annum from the date of filing the complaint, along with attorney fees amounting to ₱10,000.
Appeal to the Court of Appeals
In the following appeal, the Court of Appeals dismissed Manzano's claims, arguing that Despabiladeras had effectively engaged the court by providing contrary evidence to the admissions and that the issues of payment were not resolved definitively. This led to further questions regarding the legal consequences of not responding to requests for admission.
Supreme Court Decision
The Supreme Court ultimately ruled that Despabiladeras's failure to respo
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Case Background
- In 1989, during August and September, Luz Despabiladeras (respondent) purchased construction materials from Roger Manzano (petitioner) on credit for a project at the Camarines Sur Polytechnic Colleges (CSPC).
- The total value of the delivered materials amounted to P307,140.50, with an 8% monthly interest charge applicable until full payment was made.
- Respondent paid only P130,000.00, excluding interest, despite having received payments from CSPC.
- On April 6, 1990, petitioner filed a complaint against respondent for the sum owed, along with prayers for damages and a supplier’s lien on payments due to respondent from CSPC.
Procedural History
- Respondent countered by alleging that petitioner had altered the prices of the materials and claimed additional payments made via two checks totaling P57,069.00.
- Petitioner contended these checks were for past obligations unrelated to the current case.
- The trial court granted petitioner’s motion to establish a supplier’s lien and ordered CSPC to withhold P201,711.74 pending litigation.
- Petitioner filed a bond of P50,000.00 as required by the court.
Pre-Trial and Admissions
- During the pre-trial, both parties acknowledged some deliveries but disputed the costs.
- The court ordered petitioner to submit an itemized list of materials with costs, to which respondent could respond with objections.
- Instead of complying, petitioner filed a Request for Admission of various facts regarding the deliveries and payments, which respondent did not answer u