GR 184971; (April, 2010) (Digest)
G.R. No. 184971 , April 19, 2010
Land Bank of the Philippines, Petitioner, vs. Monet’s Export and Manufacturing Corp., Vicente V. Tagle, Sr. and Ma. Consuelo G. Tagle, Respondents.
FACTS
Petitioner Land Bank of the Philippines (Land Bank) extended a credit line to respondent Monet’s Export and Manufacturing Corporation (Monet), secured by a continuing guaranty from respondent spouses Vicente V. Tagle, Sr. and Ma. Consuelo G. Tagle. Land Bank filed a collection suit claiming Monet’s obligation had reached ₱11,464,246.19. The Regional Trial Court (RTC) based its decision on Exhibit 39, a Schedule of Amortization covering only one promissory note (P-981) for ₱2.5 million, and ordered payment of that amount. The Court of Appeals affirmed. In a prior petition ( G.R. No. 161865 ), the Supreme Court remanded the case to the RTC for reception of additional evidence to determine the actual indebtedness, noting that Exhibit 39 covered only a fraction of the claimed amount and that multiple promissory notes existed. On remand, Land Bank’s counsel stated at the hearing that he had no more documents to present. The RTC then reinstated its original decision based on Exhibit 39. Land Bank filed a motion for reconsideration (a motion to reopen) to present an updated Consolidated Billing Statement as of October 31, 2006, but the RTC denied it. The CA affirmed the denial, holding that the billing statement was insufficient evidence, akin to a prior Consolidated Statement of Account deemed insufficient by the Supreme Court.
ISSUE
Whether the RTC and the CA acted correctly in denying petitioner Land Bank’s motion to reopen the hearing to allow it to present an updated Consolidated Billing Statement to prove respondents’ remaining indebtedness.
RULING
No. The Supreme Court granted the petition, set aside the CA and RTC orders, and remanded the case to the RTC for reception of evidence. The Court held that the original RTC decision was incomplete as it failed to resolve the main issue of the exact indebtedness, relying solely on Exhibit 39 which covered only one promissory note despite evidence of multiple loans. The Court ruled that a bank statement, such as the Consolidated Billing Statement Land Bank sought to present, if properly authenticated by a competent bank officer, can serve as evidence of the status of loan accounts under Section 43, Rule 130 of the Rules of Court, as entries made in the regular course of business are prima facie evidence of the facts stated therein. The RTC and CA erred in requiring the presentation of all original documents for every transaction. The case was remanded to determine the actual indebtedness after reconciling all loan accounts.