GR 129189; (December, 2000) (Digest)
G.R. No. 129189 , December 1, 2000
DONATO C. CRUZ TRADING CORPORATION, Petitioner vs. COURT OF APPEALS AND TERESA R. JALANDONI, Respondent
FACTS
Petitioner Donato C. Cruz Trading Corporation filed a complaint for collection of sum of money against respondent Teresa R. Jalandoni before the Regional Trial Court (RTC) of Bacolod City. The corporation alleged that Jalandoni purchased 100 bags of fertilizer on credit but failed to pay despite repeated demands. The RTC declared Jalandoni in default for failure to file an answer, allowing the petitioner to present evidence ex parte. This evidence included an Order Slip and a Charge Invoice purportedly bearing Jalandoni’s name and signature, as well as demand letters.
The RTC dismissed the complaint for lack of sufficient evidence, finding fatal defects in the petitioner’s documentary evidence. The trial court noted that the Order Slip did not clearly indicate it was Jalandoni’s form, contained blank spaces, and featured signatures that were not conclusively shown to be hers or made by a duly authorized agent. The Court of Appeals affirmed this dismissal, ruling that the petitioner failed to discharge its burden of proof to establish Jalandoni’s obligation by preponderance of evidence.
ISSUE
Whether the Court of Appeals erred in affirming the trial court’s dismissal of the complaint, thereby ruling that the petitioner failed to sufficiently prove the respondent’s liability for the unpaid fertilizer.
RULING
Yes, the Supreme Court reversed the decisions of the lower courts. The legal logic centers on the evaluation of evidence in light of the respondent’s default and contumacious conduct. In civil cases, the plaintiff must prove its claim by a preponderance of evidence. While the trial court focused on perceived ambiguities in the documents, the Supreme Court held that the totality of the evidence presented ex parte was sufficient to establish a prima facie case.
The Order Slip and Charge Invoice, coupled with the unrebutted testimony of the petitioner’s witness, adequately showed the transaction and the respondent’s receipt of the goods. Crucially, the respondent’s procedural behavior was telling. Her failure to file an answer, which led to the default order, and her subsequent repeated failure to comply with Supreme Court directives to file a comment, amounted to indirect contempt. This obstinate refusal to participate in the proceedings or to specifically deny the allegations, choosing instead to merely parrot the lower court’s findings, was interpreted by the Court as an evasion of a just obligation. The respondent’s silence and defiance, in the face of the petitioner’s evidence, bolstered the credibility of the claim. Consequently, the Supreme Court found the evidence sufficient to establish the respondent’s liability.