Case Summary (G.R. No. 127997)
Factual Background
On June 30, 1991, Villanueva issued a check amounting to P167,600.00 to Manuel, allegedly as payment for loans previously availed from Manuel to support Villanueva's mining and fertilizer business. After the check bounced, Manuel demanded payment, which Villanueva failed to fulfill. Consequently, Manuel initiated a civil suit for recovery of the amount and also filed a criminal complaint against Villanueva for violation of Batas Pambansa Bilang 22. Villanueva contested the amount owed, asserting his principal obligation was only P23,420.00.
Trial Court Decision
The Regional Trial Court ruled in favor of Manuel on July 27, 1992, ordering Villanueva to pay the full amount of P167,600.00 with costs against Villanueva, while dismissing the case against Melchora Villanueva. Both parties subsequently appealed the decision to the Court of Appeals, with Villanueva challenging the awarded amount and Manuel seeking additional claims for attorney’s fees and damages.
Court of Appeals Ruling
The Court of Appeals dismissed Villanueva’s appeal and upheld the trial court's ruling, modifying it to include an award of attorney’s fees and litigation expenses at ten percent of the principal amount, along with accruing interest at six percent per annum from the filing of the complaint. Villanueva subsequently sought further review from the Supreme Court.
Issues Raised
In his petition, Villanueva raised several issues: (a) the enforceability of the interests awarded due to the lack of a written stipulation; (b) the assertion that his liability should be limited to P23,420.00; and (c) the assertion that the Central Bank and Monetary Board lack the authority to repeal the usury law.
Supreme Court’s Approach to Review
The Supreme Court noted that its jurisdiction over cases from the Court of Appeals is typically confined to matters of law, while findings of fact are generally conclusive. However, several exceptions allow for a review of factual findings if they are deemed erroneous based on certain criteria, such as a misapprehension of facts or conflicting conclusions among courts.
Findings on Legal Interest
In reviewing the case, the Supreme Court determined that Villanueva did not raise substantial issues warranting the reversal of the lower court's findings. According to established jurisprudence, when an obligation for the payment of money is breached, the interest rate is typically governed by contractual stip
...continue readingCase Syllabus (G.R. No. 127997)
Case Overview
- This case involves a petition for review by Felix Villanueva against the decision of the Court of Appeals in CA-G.R. CV 39731, relating to a civil action for the sum of money filed by Almario Go Manuel.
- The case was decided on August 07, 1998, by the Third Division of the Supreme Court, with Justice Romero as the ponente.
Factual Background
- In 1991, Almario Go Manuel filed a civil action for sum of money with damages against Felix Villanueva and his wife Melchora in the Regional Trial Court of Cebu City.
- The subject of the action was a check dated June 30, 1991, amounting to P167,600.00, issued by Villanueva to Manuel as payment for loans previously obtained for Villanueva's business.
- The check was dishonored due to insufficient funds, leading to a demand for payment that Villanueva failed to honor.
- Following the dishonor of the check, Manuel filed both a criminal complaint for violation of Batas Pambansa Bilang 22 and the civil complaint for the sum of money.
Trial Court Proceedings
- The Regional Trial Court rendered a decision on July 27, 1992, ruling in favor of Almario Go Manuel.
- The court ordered Villanueva to pay Manuel P167,600.00, dismissed the case against Melchora Villanueva, and imposed costs against Felix Villanueva.
- Both parties appealed the decision to the Court of Appeals, with Villanueva contesting the amount and Manuel seeking interest, attorney's fees, and damages.