GR 241329; (November, 2019) (Digest)
G.R. No. 241329 , November 13, 2019
Marylou B. Tolentino, Petitioner, vs. Philippine Postal Savings Bank, Inc., Respondent.
FACTS
Petitioner Marylou B. Tolentino filed a complaint for collection of a sum of money against respondent Philippine Postal Savings Bank, Inc. (PPSBI). The case stemmed from a loan obtained by Enrique Sanchez on behalf of Shekinah Construction from PPSBI. To hasten the project, Enrique borrowed P1,500,000.00 from Marylou, payable in 60 days with 5% monthly interest. PPSBI’s Loans and Evaluations Manager, Amante A. Pring, issued a letter stating PPSBI would remit P1,500,000.00 to Marylou within 60 days from her loan to Enrique. Subsequently, a Deed of Assignment was executed by Enrique and Marylou, with Amante’s conformity on behalf of PPSBI, wherein Enrique assigned the loan proceeds to Marylou. Marylou released the loan to Enrique, deducting P150,000.00 as interest. After 60 days, PPSBI did not pay Marylou and instead released the amount to Enrique. The Regional Trial Court (RTC) dismissed Marylou’s complaint, ruling PPSBI was merely a guarantor entitled to the benefit of excussion. The Court of Appeals (CA) set aside the RTC’s dismissal but ordered a remand to the RTC for trial on the merits. Marylou filed a petition for review, arguing the CA should have decided the case on the merits instead of remanding it.
ISSUE
Whether the Court of Appeals erred in remanding the case to the Regional Trial Court for further proceedings instead of resolving the merits based on the existing records.
RULING
The Supreme Court granted the petition, reversing the CA’s order of remand. The Court held that remanding the case was unnecessary because a full trial on the merits had already been conducted in the RTC, and the complete records, including all evidence presented, were elevated to the CA. The Court, in the interest of expedient justice and to avoid further delay, proceeded to resolve the substantive issues. The Court ruled that PPSBI was not a guarantor but had assumed a direct obligation to pay Marylou based on the letter and the Deed of Assignment, which constituted a stipulation pour autrui in her favor. Consequently, PPSBI was ordered to pay Marylou P1,500,000.00 with legal interest of 6% per annum from the finality of the decision until full satisfaction. The Court also found the stipulated 5% monthly interest on the loan between Marylou and Enrique to be excessive and unconscionable, reducing it to 12% per annum for the 60-day period.