Case Summary (G.R. No. 257084)
Purchase and Initial Complaints
Aguilar purchased a Toyota Wigo with a conduction sticker from TFI on an installment basis. Shortly after the purchase, she encountered multiple issues with the vehicle, including a malfunctioning steering wheel and noises emanating from the brake and accelerator pads. Despite numerous repairs conducted by TFI, the issues persisted, prompting Aguilar to file a complaint with the DTI for product imperfections under the Consumer Act.
DTI Adjudication Division's Decision
On October 25, 2016, the DTI Adjudication Division ruled in favor of Aguilar, ordering TMP to replace the defective vehicle and pay an administrative fine of ₱240,000. The Division noted that TMP failed to present substantial evidence to counter Aguilar's claims and highlighted the potential safety risks associated with the vehicle's unresolved imperfections. Though Aguilar sought a refund, the Division concluded that a replacement was more appropriate due to the vehicle's warranty.
DTI Secretary's Ruling
On February 24, 2018, the DTI Secretary upheld the decision of the Adjudication Division, asserting that TMP was liable for the express imperfections due to the delayed repairs that exceeded thirty days. The Secretary also noted that TFI exhibited bad faith by allowing the installation of an aftermarket alarm system, which could potentially harm the vehicle, without informing Aguilar.
Court of Appeals' Decision
The Court of Appeals dismissed TMP’s appeal, affirming the findings of the DTI and rejecting the claim that TMP was denied due process. The CA emphasized that technical rules in administrative proceedings are more flexible, and both parties had opportunities to present their cases during mediation. Furthermore, it reaffirmed the liability of TMP and TFI under Article 100(a) of the Consumer Act due to the persistent defects in the vehicle.
Arguments Presented by TMP
In the petition for certiorari, TMP argued that it was denied due process by the DTI when its position paper was not considered before the ruling. TMP also claimed that the steering issue was exacerbated by Aguilar’s installation of an unauthorized alarm syst
...continue readingCase Syllabus (G.R. No. 257084)
Introduction
- The case involves a petition for review on certiorari filed by Toyota Motors Philippines Corporation (TMP) against Esmeralda M. Aguilar and Toyota Fairview, Inc. (TFI).
- The petition contests the Decision dated December 7, 2020, and Resolution dated June 29, 2021, of the Court of Appeals (CA) in CA G.R. SP No. 155872.
Facts of the Case
- Esmeralda Aguilar purchased a Toyota Wigo on an installment basis from TFI, which was released with Conduction Sticker No. VB4772.
- Shortly after the purchase, Aguilar experienced multiple issues with the vehicle, including steering wheel malfunction and noises from the brake and accelerator pads.
- The vehicle underwent several repairs from June to September 2016, but no repair orders were issued by TFI.
- Aguilar filed a complaint with the Department of Trade and Industry (DTI) Adjudication Division alleging product and service imperfections under the Consumer Act.
Ruling of the DTI Adjudication Division
- On October 25, 2016, the DTI Adjudication Division ruled in favor of Aguilar, ordering TMP to replace the defective vehicle and pay an administrative fine of PhP 240,000.
- The ruling emphasized TMP's failure to present substantial evidence to rebut Aguilar's claims and noted the persistent issue with the vehicle's steering wheel as a significant safety concern.
- The Division denied Aguilar's request for a refund but recognized the warranty as applicable since the imperfection was discovered within two months of purchase.
- Aguilar's claim under the Philippine Lemon Law was denied due to lack of proof of the required written notice.