G.R. No. 226495, February 05, 2020
Spouses Dennis and Cherrylyn “Cherry” Garcia, doing business under the name and style of Ecolamp Multi-Resources, Petitioners, vs. Northern Islands, Co., Inc., Respondent.

FACTS

Respondent Northern Islands, Co., Inc. (Northern) filed a Complaint for Sum of Money with Damages against petitioner Spouses Dennis and Cherrylyn Garcia, doing business as Ecolamp Multi-Resources (Ecolamp). Northern alleged that from March to July 2004, Ecolamp ordered various 3D home appliances with an aggregate value of P8,040,825.17, which were shipped and delivered to Ecolamp in Davao City via Sulpicio Lines, Inc. The obligation was payable within 120 days from receipt, with unpaid amounts earning 18% interest per annum. Despite demands, Ecolamp failed to pay. The Spouses Garcia denied receipt of any deliveries for that period, asserting that the signatory on the delivery receipts was not authorized and that Northern failed to submit sales invoices proving the indebtedness. The Regional Trial Court (RTC) dismissed the complaint, ruling that the delivery documents lacked significance without the primary evidence of purchase orders and sales invoices, and that Northern failed to justify the presentation of secondary evidence. The Court of Appeals (CA) reversed the RTC, finding that Northern proved its case by preponderance of evidence. The CA, in its Amended Decision, ordered the Spouses Garcia to pay P6,478,700.00 with interest. The Spouses Garcia filed the present Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in finding that respondent Northern Islands, Co., Inc. proved by preponderance of evidence the existence of a perfected contract of sale and the delivery of goods, thereby establishing Ecolamp’s obligation to pay the sum of money.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Amended Decision of the Court of Appeals. The Court held that in a civil case for sum of money, the burden of proof is on the party asserting the affirmative issue, to be established by preponderance of evidence. The Court found that Northern proved its cause of action by preponderance of evidence. Although Northern failed to present the sales invoices, it presented delivery cargo receipts showing deliveries to Ecolamp from April to July 2004, corroborated by the testimonies of Sulpicio Lines personnel who stated that a representative named Alvin received the goods on Ecolamp’s behalf. Cherrylyn Garcia’s testimony that Ecolamp’s employees were authorized to receive deliveries, coupled with her failure to specifically disclaim Alvin as an employee, bolstered this finding. The deliveries created an obligation on Ecolamp to pay, and the Spouses Garcia failed to present evidence of payment. The Court sustained the CA’s imposition of 12% interest per annum from the date of extrajudicial demand (May 4, 2005) until June 30, 2013, and 6% per annum from July 1, 2013 until finality of the decision, with the total amount earning 6% interest per annum until fully paid. The other issues raised by the petitioners were deemed factual and thus not reviewable in a Rule 45 petition, which is limited to errors of law.