GR 151790; (April, 2008) (Digest)
G.R. No. 151790 ; April 22, 2008
SPOUSES ABNER AND ESTRELLA ANCHINGES, petitioners, vs. SPOUSES FERMIN AND LORNA ALBARILLO and LENIDA ANCHINGES, respondents.
FACTS
Petitioners Spouses Abner and Estrella Anchinges purchased a portion of Lot No. 9-B-1 from Abner’s uncle, Nicanor del Mundo. With del Mundo’s permission, they constructed a two-unit duplex residential house, partly on their purchased lot and partly on the adjacent Lot No. 9-B-2. The second unit was intended for their parents. In 1983, respondents Spouses Fermin and Lorna Albarillo (Abner’s sister) and Lenida Anchinges (another sister) purchased Lot No. 9-B-2 and moved into the second unit. A dispute arose over construction expenses, leading petitioners to file an ejectment case, which was dismissed without prejudice to a money claim.
Petitioners subsequently filed a complaint for sum of money and damages before the RTC, alleging they constructed 95% of the second unit, that respondents occupied it without their knowledge, and that respondents refused to reimburse the construction costs of P160,000 or pay reasonable rent. The RTC ruled in favor of petitioners, ordering respondents to pay P160,000 and, alternatively, rental arrears. The Court of Appeals reversed the RTC decision, dismissing the complaint.
ISSUE
Whether the Court of Appeals erred in dismissing petitioners’ complaint for reimbursement of construction expenses and damages.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle is that in civil cases, the party alleging a claim must prove it by a preponderance of evidence. Petitioners failed to discharge this burden. Their evidence was insufficient to establish that the second unit was 95% complete when respondents moved in or that respondents had an obligation to reimburse them. The “Bill of Materials and Cost Estimates” presented did not specify which unit it referred to, totaled only P114,371 (not the claimed P160,000), and lacked proof of actual disbursement. Crucially, petitioner Abner admitted receiving P100,000 from their mother, Natividad, for the construction. Respondents countered with receipts and invoices in Lorna’s name for construction materials and a payment schedule signed by Abner acknowledging receipt of P40,000 as partial reimbursement. The Court found petitioners’ evidence unconvincing and respondents’ evidence more credible, thus upholding the appellate court’s finding that petitioners failed to prove their case by preponderant evidence.