Case Summary (G.R. No. 236920)
Factual Background
On February 20, 2004, Ridao entered into a loan agreement with Handmade Credit securing $4,000, which was later increased on August 24, 2004, resulting in a total financial obligation of $6,167 and an additional loan of P40,000. Ridao asserted that she made multiple payments totaling $4,300 towards her obligation, claiming that these payments were facilitated through her husband, Avelino, who recorded them in a ledger. She denied the validity of any additional loans and alleged that any related documents presented by Handmade Credit were altered and forged.
Proceedings Before the Regional Trial Court
In response to non-payment allegations, Handmade Credit filed a complaint for collection in the Regional Trial Court (RTC) of Urdaneta City, emphasizing that Ridao did not pay her obligations. Citing several annexes to support their claims, the RTC allowed evidence regarding the ledger presented by Ridao, which indicated payments made through Avelino. The RTC ultimately ruled in favor of Ridao, declaring that her payments satisfied the debt and found the original loan terms to be unconscionable due to excessive interest rates.
Court of Appeals' Ruling
Handmade Credit appeal to the Court of Appeals, which resulted in a modified ruling. The CA deemed the promissory notes void due to evidence of material alterations, yet ordered Ridao to pay a reduced amount of $3,200 with interest, asserting that Ridao had the burden to prove the payment of the remaining balance despite acknowledging part of the debt. The appellate court raised concerns about the ledger's authenticity and the lack of clarity regarding several entries.
Issue for Review
The principal issue before the Supreme Court was whether the Court of Appeals committed reversible error in ordering Ridao to pay the amount determined despite previous findings in her favor by the trial court.
Supreme Court's Analysis
The Supreme Court found the petition meritorious, emphasizing that Ridao's submission of the ledger should have shifted the burden of proof to Handmade Credit regarding any claims of non-payment. The Court reiterated that failure to deny the ledger's authenticity did not equate to admitting it as an actionable document since it did not set forth the precise terms of the loan. Nonetheless, the Court acknowledged its admissibility for consideration in proving payments made.
Findings on Loan Payments
The Supreme Court meticulously evaluated the testimonies and evidence presented. It was noted that Teofilo admitted accepting a significant portion of the payments made by Ridao through her husband. The absence of documentary evidence from Handmade Credit to support its non-payment assertions under
...continue readingCase Syllabus (G.R. No. 236920)
The Case
- This case involves a Petition for Review on Certiorari challenging the Decision dated August 16, 2017, and the Resolution dated January 11, 2018, of the Court of Appeals (CA) in CA-G.R. CV No. 107564.
- The petitioner in the case is Gemma A. Ridao, while the respondent is Handmade Credit and Loans, Inc., represented by Teofilo V. Manipon.
The Facts
- On February 20, 2004, Gemma A. Ridao obtained a loan of $4,000.00, documented by Promissory Note No. 2000029B, from Handmade Credit, a lending corporation. Teofilo Manipon, Ridao's brother-in-law, was the authorized representative of Handmade Credit.
- On August 24, 2004, Ridao secured an additional loan which raised her total obligation to $6,167.00, again documented by Promissory Note No. 2000029B, along with a separate loan of P40,000.00.
- Both loans carried a 4% monthly interest and were to be paid within a year.
- Due to non-payment, Handmade Credit sent a Demand Letter dated September 21, 2012, requesting the payment of the outstanding amounts.
- Following Ridao's failure to respond, Handmade Credit filed a complaint for collection of sums owed with the Regional Trial Court (RTC) of Urdaneta City, Pangasinan, on July 11, 2013.
- The complaint included the relevant promissory notes, statements of loan release, and asserted that Ridao had not made any payments towards her obligations.
- In her answer, Ridao admitted to the initial loan but claimed that it was a familial transaction rather than a forma