GR 116682; (January, 1997) (Digest)
G.R. No. 116682 January 2, 1997
Roblett Industrial Construction Corporation, petitioner, vs. Court of Appeals and Contractors Equipment Corporation, respondents.
FACTS
Respondent Contractors Equipment Corporation (CEC) filed a collection suit against petitioner Roblett Industrial Construction Corporation (RICC) for unpaid rentals of leased construction equipment. The core evidence was an Agreement dated December 19, 1985, signed by RICC’s Assistant Vice President for Finance, Candelario S. Aller Jr., confirming an outstanding balance of P342,909.38. This amount was partially offset by construction materials worth P115,000.00 delivered by RICC to CEC, reducing the balance to P227,909.38. The balance later increased to P237,909.38 after P10,000.00 in postdated checks issued by RICC were dishonored. CEC sent a formal demand, to which RICC requested a 30-day extension to settle, without contesting the amount.
In its defense, RICC claimed the Agreement did not reflect the true obligation, arguing that based on selected Equipment Daily Time Reports, it only owed P103,140.00 for 191 hours of use. It further contended that the P115,000.00 offset resulted in a P12,000.00 overpayment. RICC also asserted that Aller Jr. lacked authority to bind the corporation, as the Agreement was not approved by its Board.
ISSUE
The primary issues were: (1) whether the Agreement was valid and binding upon RICC; and (2) whether RICC had fully paid or overpaid its obligation to CEC.
RULING
The Supreme Court denied the petition and affirmed the lower courts’ decisions. On the first issue, the Court held that RICC was estopped from questioning the validity of the Agreement or the authority of its signatory. RICC’s failure to specifically deny under oath the genuineness and due execution of the Agreement in its Answer constituted a judicial admission under the Rules of Court. More importantly, RICC’s conduct—specifically, receiving CEC’s statement of account without protest and requesting an extension to settle the demanded amount—constituted estoppel in pais. By its representations and silence, RICC induced CEC to believe the debt was acknowledged, precluding it from later denying the Agreement’s validity.
On the second issue, the Court found no reason to disturb the factual findings of the trial court and the Court of Appeals. RICC’s evidence, limited to daily time reports for a partial period (May 2 to June 14, 1985), was incomplete and did not refute CEC’s comprehensive evidence covering the entire lease period from March 28 to July 12, 1985. The trial court correctly found that CEC accurately established the total obligation. The petition, therefore, failed to show any compelling reason for the Supreme Court to overturn these factual conclusions, which are generally binding.