GR 103737; (December, 1994) (Digest)
G.R. No. 103737 December 15, 1994
Nora S. Eugenio and Alfredo Y. Eugenio, petitioners, vs. Hon. Court of Appeals and Pepsi-Cola Bottling Company of the Philippines, Inc., respondents.
FACTS
Private respondent Pepsi-Cola Bottling Company filed a complaint for a sum of money against petitioner spouses, alleging that they had an outstanding account of P94,651.00 from credit purchases of soft drink products and loaned empties from its Quezon City and Muntinlupa plants. Petitioners defended by presenting four Trade Provisional Receipts (TPRs) showing payments totaling P80,560.00 made to Pepsi’s Malate warehouse. They contended that crediting these payments would extinguish the debt and even result in an overpayment. They also alleged that a sales invoice for P5,631.00 bore a falsified signature. The trial court initially ordered petitioners to pay P74,849.00. After the Court of Appeals remanded the case for a decision compliant with constitutional requirements, the trial court rendered a new decision ordering payment of P64,188.60, which the Court of Appeals affirmed.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s decision, which failed to credit the payments evidenced by the TPRs against petitioners’ alleged obligations.
RULING
Yes. The Supreme Court reversed the Court of Appeals. The legal logic centers on the burden of proof and the evaluation of evidence. While the general rule restricts Supreme Court review to questions of law, an exception applies when lower courts overlook relevant facts causing a misapprehension. Here, the TPRs were crucial evidence of payment. Pepsi-Cola’s sole witness, its credit and collection manager, admitted the TPRs were genuine company documents but claimed they represented transactions with a different dealer, “Abigail’s Store,” not petitioners’ “Abigail Minimart.” This claim was unsupported by any independent evidence, such as ledger entries for “Abigail’s Store,” and relied on a self-serving, unverified list.
The Court found Pepsi-Cola failed to discharge its burden of proof. Petitioners, by presenting the TPRs, successfully shifted the burden of evidence to Pepsi-Cola to prove the payments were not meant for their account. Pepsi’s reliance on the purported list, without corroboration, was insufficient to overcome the prima facie validity of the receipts. Furthermore, the alleged falsification of one sales invoice was not convincingly proven. Consequently, crediting the TPR payments established that petitioners had overpaid by P5,710.60. The Supreme Court thus annulled the appellate decision and ordered Pepsi-Cola to refund the overpayment to petitioners.