Case Summary (G.R. No. 211724)
Factual Antecedents
In February 2001, Lolita Alcazar, the proprietor of Legazpi Color Center (LCC), filed a complaint against spouses Fernando and Ma. Elena Santos for a sum of money, claiming they owed P1,456,000, which included unpaid dues for paint and construction materials acquired from LCC. This complaint was based on a hand-executed acknowledgment by petitioner Fernando T. Santos confirming their obligation. The case was assigned to Branch 5 of the Regional Trial Court of Legazpi City, identified as Civil Case No. 9954.
The Acknowledgment Document
The relevant document, titled "Acknowledgment," declared Fernando's debt to LCC. The acknowledgment was signed by Fernando and included witnesses, indicating the date of signing and acknowledging the debt's existence. The respondent stipulated in her complaint that the petitioners were obligated to pay an interest rate of 3% monthly on the unpaid principal, amounting, as per her calculation, to a total obligation of P1,456,000 by December 2000. Despite demands for payment made to the Santos couple, no response was received.
Responses and Counterclaims
In their formal answer, petitioners accepted they had transaction dealings with Alcazar but sought to dismiss the complaint, asserting that the acknowledgment document did not accurately reflect their true indebtedness. They claimed that only P600,000 was due, thus indicating a need for reformation of the acknowledgment. They also stated the absence of original receipts to support the terms alleged by the respondent.
Trial Proceedings
The trial court conducted a pre-trial conference, during which evidence presentation was scheduled. The respondent presented evidence including her testimony, which was considered sufficient for her claims. The petitioners countered with a demurrer to the evidence, arguing the lack of authenticity and admissibility regarding the acknowledgment, but this was denied by the trial court.
Court Rulings
The trial court eventually ruled in favor of Alcazar, awarding her the full amount of P1,456,000 plus interest and additional litigation costs. The court found the petitioners had admitted their owed amount through their answer and decided that the acknowledgment sufficed to establish their liability without the need for original receipts or delivery proofs. The petitioners filed a motion for reconsideration, which was denied, prompting them to appeal to the Court of Appeals.
Court of Appeals Decision
The Court of Appeals upheld the trial court’s decision, emphasizing that the acknowledgment's genuineness had not been specifically denied under oath by the petitioners, thus it was assumed to be valid. They affirmed that petitioners were afforded multiple opportunities to present evidence and had waived their rights through various dilatory actions. The appellate court concluded that the acknowledgment document sufficiently established the Santos’ liability.
Issues Raised by Petitioners
In a petition for review, the petitioners contended that the Court of Appeals failed to properly consider their arguments regarding the lack of original documentation and the procedural irregularities in the pre-trial process. They maintained that Fernando's acknowledgment only bound him and did not extend liability to Ma. Elena Santos.
Supreme Court Ruling
The Supreme Court ruled to deny t
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Background of the Case
- This case involves a Petition for Review on Certiorari filed by petitioners Fernando and Ma. Elena Santos against respondent Lolita Alcazar, represented by her attorney-in-fact, Delfin Chua.
- The case was previously decided by the Court of Appeals (CA) in CA-G.R. CV No. 87935 on September 27, 2007, which upheld the trial court's ruling.
Factual Antecedents
- In February 2001, respondent Lolita Alcazar, owner of Legazpi Color Center, filed a Complaint for sum of money against the petitioners to recover the unpaid value of paint and construction materials amounting to P1,456,000.00.
- This debt arose from an acknowledgment document signed by petitioner Fernando T. Santos, which stated his obligation to pay the cited amount to the Legazpi Color Center.
- Respondent alleged that the petitioners had also agreed to pay interest at the rate of 3% per month on the unpaid principal.
Petitioners' Response
- The petitioners contested the complaint, claiming that the acknowledgment document did not reflect the true contract and sought reformation of the instrument.
- They specifically denied the total amount claimed by the respondent, asserting that only P600,000.00 was due.
Procedural History
- A pre-trial conference was conducted, and the trial court noted the schedules for the presentation of evidence.
- Respondent presented her evidence, including her testimony and the acknowledgment document, which was formally offered in court.
- Petitioners filed a Demurrer to Evidence, arguing that the acknowledgment was not an original