GR 26292; (February, 1970) (Digest)
G.R. No. L-26292 February 18, 1970
SANTIAGO VIRGINIA TOBACCO PLANTERS ASSOCIATION, INC., plaintiff-appellee, vs. PHILIPPINE VIRGINIA TOBACCO ADMINISTRATION and FARMERS’ VIRGINIA TOBACCO REDRIERS INC., defendants-appellants.
FACTS
Plaintiff Santiago Virginia Tobacco Planters Association, Inc. (SVTPA), an authorized trading entity, filed a complaint against defendants Philippine Virginia Tobacco Administration (PVTA), a government corporation, and Farmers’ Virginia Tobacco Redriers, Inc. (FVTR), a private corporation, to recover the value of seven shipments of tobacco totaling P227,342.31, which SVTPA allegedly delivered to and were accepted by FVTR. PVTA had awarded FVTR a contract to procure, redry, and service locally grown flue-cured Virginia tobacco. PVTA denied SVTPA’s payment request, asserting the shipments were fictitious and not supported by primary tally sheets from its grader at the FVTR plant. FVTR admitted receiving the shipments but claimed it acted merely as PVTA’s agent. The trial court rendered a joint and several judgment against both defendants. Both PVTA and FVTR appealed.
ISSUE
The primary issue is whether SVTPA presented sufficient evidence to prove that the seven shipments of tobacco were actually delivered to and accepted by FVTR.
RULING
The Supreme Court reversed the trial court’s judgment and dismissed SVTPA’s complaint. The Court held that SVTPA failed to meet the burden of proof required to establish the deliveries. SVTPA’s evidence, consisting of shipping documents, checklists, and tally sheet summaries, was deemed insufficient and unreliable. Critical documents, such as the primary tally sheets (tally-n-sheets) which were required by the PVTA-FVTR agreement as the best evidence of actual delivery and acceptance, were not presented. Instead, SVTPA presented summaries and certificates signed by FVTR’s president, which the Court found to be of doubtful authenticity and contradicted by other evidence. Notably, for two of the shipments (guias 28 and 29), the PVTA clearance authorized delivery to other redriers, not to FVTR, indicating a false claim. The fabrication or suppression of evidence was taken as an indication of the weakness of SVTPA’s case. Consequently, the claim was unsubstantiated.