G.R. No. 105997 September 26, 1997
Spouses Mario and Carmelita Bella, petitioners, vs. Court of Appeals, Industrial Finance Corporation and Ben Medina alias “Ben Untog,” respondents.

FACTS

Petitioner Mario Bella purchased a car from GM Automart Corporation, executing a Deed of Sale with Chattel Mortgage and a Promissory Note for P53,390.88 payable in 36 monthly installments. The rights under the note were assigned to respondent Industrial Finance Corporation (IFC). Mario Bella made fourteen installment payments of varying amounts from August 1978 to October 1979 but subsequently defaulted. After demands, IFC filed a complaint for sum of money against the spouses Bella, who in turn filed a third-party complaint against Benjamin Untog.
The Regional Trial Court rendered judgment in favor of IFC, ordering the Bellas to pay P25,212.30 with penalty and attorney’s fees, and dismissed the third-party complaint. On appeal, the Court of Appeals affirmed but modified the award to P32,725.61. The Bellas filed this petition, arguing IFC failed to prove the specific obligation, that the appellate court erred in increasing the award without an appeal by IFC, that IFC’s answer to a request for admission was filed late, and that the third-party defendant should be held liable.

ISSUE

The primary issues are: (1) whether the Court of Appeals erred in modifying the monetary award despite the absence of an appeal by IFC; and (2) whether the factual findings of the lower courts on the existence and amount of the petitioners’ liability are binding.

RULING

The Supreme Court partially granted the petition. On the first issue, the Court held that the Court of Appeals erred in increasing the award. A modification unfavorable to the appellant (the Bellas) is not permitted when the appellee (IFC) did not appeal. The appellate court is limited to granting affirmative relief only to the appellant. Since IFC did not appeal the trial court’s computation, the Court of Appeals could not award a higher amount.
On the second issue, the Court affirmed the factual findings of the trial court regarding the existence of the obligation. The promissory note, chattel mortgage, and disclosure statement duly signed by Mario Bella constituted sufficient proof of the debt. His liability was further corroborated by his failure to dispute the demand. Factual assessments by the trial court are generally conclusive and binding. The Supreme Court found no compelling reason to deviate from this rule, as none of the established exceptions for factual review were present. Consequently, the trial court’s computation of the unpaid balance at P25,212.30 was reinstated. The penalty and attorney’s fees as awarded by the trial court were affirmed.