G.R. No. 152922 ; July 12, 2006
DAKILA TRADING CORPORATION, petitioner, vs. PROFESSIONAL SERVICES, INC., respondent.

FACTS

Petitioner Dakila Trading Corporation and respondent Professional Services, Inc. (owner of Medical City General Hospital) entered into a Lease-Purchase Agreement for a laboratory analyzer. The contract stipulated that rental consideration was based on the number of tests performed daily, with a minimum of 150 tests per day at a graduated rate. Ownership would transfer to the respondent after two years upon full payment. Petitioner later alleged that, based on the volume of reagents ordered by the respondent for the machine’s operation, the respondent had conducted and failed to report a significant number of tests in excess of the daily minimum, leading to an unpaid balance.
After a series of communications where petitioner reduced its claim to P1,684,219.82, respondent maintained it was only liable for the minimum tests. Petitioner filed a collection case. The Regional Trial Court ruled in favor of the petitioner, ordering payment of the sum. The Court of Appeals reversed this decision, dismissing the complaint and ordering the petitioner to transfer ownership of the equipment, prompting this petition.

ISSUE

Whether the Court of Appeals erred in reversing the trial court’s finding that respondent is liable for the value of unreported excess tests conducted on the leased equipment.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the trial court’s decision. The Court, while generally not a trier of facts, reviewed the evidence as the appellate court’s findings contradicted those of the trial court. The legal logic centered on the burden of evidence in civil cases.
The contract explicitly tied payment to the actual number of tests conducted. Petitioner established a prima facie case by presenting documentary and testimonial evidence, particularly reagent orders, which logically indicated test volumes far exceeding the daily minimum. The computation based on these orders supported the claim for unpaid tests. The burden then shifted to the respondent to rebut this evidence.
Respondent failed to discharge this burden. It did not present crucial evidence within its control, such as the machine’s daily logbook or patient charge slips, which would have directly proven the actual number of tests performed. Its mere denial, without contrary proof, was insufficient to overcome petitioner’s evidence. Consequently, respondent’s liability for the unreported tests amounting to P1,684,219.82 was upheld, with 12% interest from the filing of the complaint. Upon full payment, petitioner is ordered to transfer ownership of the equipment to the respondent.