G.R. No. 217044 - Spouses Yulo vs. Bank of the Philippine Islands

October 9, 2006: Issuance of pre-approved credit card to Rainier; extension card to Juliet
July 2008: Petitioners begin to default on payments
November 11, 2008 & February 12, 2009: BPI issues demand letters
February 23, 2009: Complaint filed before Metropolitan Trial Court (MTC) Makati City
June 29, 2012: MTC decision ordering payment of P229,378.68
June 26, 2013: RTC Branch 62 affirms MTC decision
February 20, 2015: Court of Appeals (CA) denies petition for review
January 16, 2019: Supreme Court decision

1987 Philippine Constitution (as decision date is post-1990)
Civil Code provisions on contract, agency, and demand (Arts. 1169, 1868–1869)
Jurisprudence: Alcaraz v. CA (2006), Ledda v. BPI (2012), Nacar v. Gallery Frames (2013)

BPI issued credit cards without application forms to pre-screened clients.
Rainier’s authorized representative, Jessica Baitan, signed a delivery receipt but her authority relationship was unproven.
Petitioners used their cards for goods and services, initially paid regularly, then defaulted.

Outstanding balance reached P264,773.56 by November 29, 2008.
BPI sent two demand letters and filed a complaint for sum of money.
Petitioners admitted card use but disputed liability beyond P20,000, asserting nondisclosure of terms.

MTC upheld BPI’s proof of breach of terms and conditions.
Equitably reduced contractual interest and penalties from 3% to 1% per month from demand.
Awarded P229,378.68 plus 1% interest, 1% penalty per month, and P15,000 attorney’s fees.

RTC affirmed that delivery receipt and card use proved consent to terms.
Charge slips and unchallenged statements of account established liability.
CA agreed, emphasizing Rainier’s familiarity with contracts and failure to dispute charges timely.

Whether petitioners are bound by the terms and conditions governing the use of their pre-approved credit cards absent clear proof of their consent.

Pre-screened card issuance dispenses with application; provider must prove recipient’s knowledge and consent to terms.
Delivery receipt alone, marked “Authorized Representative,” was insufficient to prove that Rainier authorized Baitan or that he read and agreed to the terms.
Without proof of agency or consent, petitioners cannot be bound by contractual rates and penalties.

Usage created an obligation to pay for availed credit accommodation, but contractual terms require express or implied consent.
Rainier admitted receipt of statements and non-dispute of pre-default transactions, establishing underlying indebtedness absent terms.

Following Alcaraz and Ledda, failure to prove client’s consent to card terms limits liability to principal amount plus legal interest.

Petition for Review on Certiorari under Rule 45 filed by Spouses Rainier Jose M. Yulo and Juliet L. Yulo (petitioners) assails: • February 20, 2015 CA Decision in CA-G.R. SP No. 131192
• June 26, 2013 RTC Decision, Branch 62, Makati City, Civil Case No. 12-945
• June 29, 2012 MTC Decision, Branch 65, Makati City, Civil Case No. 97470
Timeline of actions: • Oct. 9, 2006: BPI issues pre-approved credit card to Rainier; extension card to Juliet
• July 2008: Spouses become delinquent in payments
• Nov. 11, 2008 & Feb. 12, 2009: BPI sends demand letters
• Feb. 23, 2009: BPI files sum-of-money complaint before MTC
• MTC renders decision June 29, 2012
• RTC dismisses appeal June 26, 2013
• CA denies petition Feb. 20, 2015
• SC en banc decides January 16, 2019

BPI issued Rainier a pre-approved credit card; Juliet received a supplement card on his account.
The couple used their cards to charge goods and services and initially settled monthly balances.
By November 29, 2008, their unpaid balance had ballooned to ₱264,773.56.
BPI sent formal demand letters for ₱253,017.62 (Nov. 11, 2008) and ₱325,398.42 (Feb. 12, 2009).
Petitioners admitted using the cards but claimed liability of only ₱20,000, alleging non-disclosure of Terms and Conditions (T&Cs).
Attempts at mediation failed; the case proceeded to trial with evidentiary presentations by both parties.

Whether petitioners Rainier and Juliet Yulo are bound by the Terms and Conditions governing the use of their pre-approved credit cards issued by BPI.

Held that BPI proved by preponderance of evidence that petitioners breached the T&Cs.
Equitably reduced the contractual 3% monthly interest and 3% penalty to 1% each, from date of demand (Feb. 12, 2009).
Ordered payment of ₱229,378.68 plus 1% interest and 1% penalty per month, and ₱15,000 attorney’s fees.