GR 156869; (June, 2012) (Digest)
G.R. No. 156869 ; June 27, 2012
POLYFOAM CHEMICAL CORP., Petitioner, vs. ELISA S. CHEN, Respondent.
FACTS
Petitioner Polyfoam Chemical Corporation filed a collection suit against respondent Elisa Chen before the Regional Trial Court (RTC) of Quezon City, seeking payment of ₱929,137.07 for foam products allegedly sold and delivered from April 1 to August 27, 1992. In her answer, Chen admitted purchasing substantial quantities but contested the amount, asserting through an attached summary (Annex “6”) that her obligations for that specific period totaled only ₱654,301.02. Polyfoam moved for summary judgment, which the RTC granted, ordering Chen to pay ₱925,117.35.
On appeal, the Court of Appeals (CA) modified the RTC decision, limiting the summary judgment to ₱654,301.02—the amount Chen explicitly admitted owing for the April-August 1992 period. The CA noted that Annex “6” also reflected additional deliveries worth ₱270,816.33 in September and October 1992, but concluded these were not part of the cause of action pleaded in the complaint. The CA remanded the case for further proceedings on the disputed balance. Polyfoam elevated the case to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in ruling that the summary judgment should be limited to ₱654,301.02, excluding Chen’s admissions for later deliveries.
RULING
The Supreme Court granted the petition and reinstated the RTC’s judgment. The Court held that a summary judgment is proper when the pleadings, admissions, and affidavits show no genuine issue of fact. Here, Chen’s answer and Annex “6” substantively admitted the core obligation. While Chen claimed the complaint covered only April-August 1992, the complaint itself used the term “approximately” regarding the period, allowing for a flexible interpretation that could encompass immediately succeeding months.
Critically, Annex “6”—which Chen herself presented as reflecting the “truth” of her account—showed a total indebtedness of ₱925,117.35, combining the April-August purchases (₱654,301.02) with the September-October deliveries (₱270,816.33). This total fell within Polyfoam’s pleaded claim of ₱929,137.07. By attaching and relying on this document, Chen effectively admitted the larger sum. Since she did not invoke prescription or otherwise deny receiving the later deliveries, no genuine issue existed as to the admitted amount. The CA thus erred in excluding the September-October obligations; a summary judgment for ₱925,117.35 was fully warranted based on Chen’s own judicial admissions.