G.R. No. 171702 February 12, 2009
MANILA MINING CORPORATION, Petitioner, vs. MIGUEL TAN, doing business under the name and style of MANILA MANDARIN MARKETING, Respondent.

FACTS

Respondent Miguel Tan, doing business as Manila Mandarin Marketing, was engaged in selling electrical materials. From August 19 to November 26, 1997, petitioner Manila Mining Corporation (MMC) ordered and received various electrical materials from Tan valued at ₱2,347,880. The agreement was for MMC to pay within 30 days from delivery, with interest of 18% per annum for late payment, and attorney’s fees equal to 25% of the claim in case of suit. MMC made partial payments totaling ₱464,636 but failed to pay the remaining balance of ₱1,883,244 despite demands. Tan filed a collection suit on September 3, 2001. During trial, after Tan presented evidence, MMC filed a Demurrer to Evidence, which was denied. MMC’s sole witness, accountant Rainier Ibarrola, testified that standard procedure required a supplier to present original sales invoices and purchase orders for payment, and the absence of stamp marks on the documents negated receipt by MMC. On rebuttal, Tan presented sales representative Wally de los Santos, who testified he delivered the originals to MMC’s accounting department and presented three customer’s acknowledgment receipts as proof. The Regional Trial Court ruled in favor of Tan, ordering MMC to pay the principal amount with interest and liquidated damages. The Court of Appeals affirmed the decision.

ISSUE

Whether or not petitioner’s obligation to pay had already legally accrued considering the allegation that respondent failed to comply with prerequisites for payment (submission of original invoices and purchase orders) imposed under petitioner’s purchase orders.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. The Court held that the petition raised a question of fact, which is beyond its power to review, as findings of fact by the Court of Appeals, especially when in agreement with the trial court, are accorded finality and are binding. The Court found no reason to overturn the lower courts’ findings. On the merits, the Court ruled that the contract of sale was perfected under Article 1475 of the Civil Code at the moment there was a meeting of minds, which occurred when Tan supplied the electrical materials to MMC upon the latter’s purchase orders. Thus, MMC could not evade its obligation by claiming lack of consent. Regarding the failure to present original documents, the Best Evidence Rule was inapplicable as the contents of the writing were not directly in issue, and photocopies were admissible to prove the contract of sale. The Court also found no merit in the claim of laches, as Tan filed the suit less than a year after MMC stopped making partial payments, and there was no neglect to assert a right under the circumstances.