G.R. No. 147575 ; October 22, 2004
Teresita B. Mendoza, petitioner, vs. Beth David, respondent.

FACTS

Petitioner Teresita Mendoza ordered custom furniture from respondent Beth David, paying a total deposit of ₱80,650. Upon delivery, Mendoza rejected the furniture, claiming it was of inferior material and poor quality compared to their oral agreement on specifications. She demanded a refund of her deposit, which David refused, leading Mendoza to file a collection case. David countered that the furniture was made to order and conformed to the agreement, and that Mendoza failed to pay the balance, prompting David to reclaim and store the delivered items.
The Metropolitan Trial Court (MTC) dismissed Mendoza’s complaint, finding a perfected contract of sale and no proof that the furniture breached agreed specifications. The Regional Trial Court (RTC) affirmed the perfected contract but modified the balance due. Mendoza appealed to the Court of Appeals (CA), which dismissed her petition for review for being insufficient in form and substance due to her failure to attach required pleadings and documents, despite later submitting them in a motion for reconsideration.

ISSUE

The primary issue is whether the Court of Appeals erred in dismissing the petition for review based on procedural grounds and in its substantive finding that there was no breach of the sale agreement.

RULING

The Supreme Court found the petition partly meritorious. On procedure, the Court held that while the CA correctly noted the initial non-compliance with Rule 42 of the Rules of Court regarding annexes, Mendoza’s subsequent submission in her motion for reconsideration constituted substantial compliance. To avoid further delay, the Supreme Court opted to resolve the case on its merits rather than remanding it.
On the substantive issue, the Court affirmed the lower courts’ findings. The contract was a sale by description under Article 1481 of the Civil Code, where the buyer may rescind if the goods do not conform to the description. However, the burden of proof rests on the buyer to demonstrate non-conformity. Mendoza failed to present sufficient evidence to prove that the delivered furniture deviated from the agreed specifications. Her mere allegation of inferior quality, unsupported by credible evidence, could not overcome the presumption of regularity in private transactions. Consequently, there was no basis to rescind the contract or order a refund of her deposit. The perfected contract imposed reciprocal obligations, and Mendoza’s failure to pay the balance justified David’s actions.