GR 92710; (February, 1991) (Digest)
G.R. No. 92710; February 27, 1991
CARLITO TULOD, doing business under the name and style of “PRECISION MOTOR WORKS,” petitioner, vs. FIRST CITY LINE TRANSPORTATION COMPANY, respondent.
FACTS
Petitioner Carlito Tulod, owner of Precision Motor Works, filed a collection suit against respondent First City Line Transportation Company for unpaid spare parts delivered from June to July 1984. Petitioner presented delivery receipts signed by the respondent’s stockman and maintenance manager, Antonio Acuña, along with corresponding purchase orders and sales invoices, to prove the transactions and subsequent demands for payment. The total claim amounted to P111,180.00.
Respondent denied the transactions, alleging no records existed and that its established company procedure for purchases was not followed. It contended the transactions were irregular, noting purchase orders were dated later than delivery receipts, prices were higher than from regular suppliers, and some deliveries occurred on a holiday when Acuña was allegedly absent. The respondent suggested the transactions were simulated and fictitious, implying Acuña acted improperly.
ISSUE
Whether the Regional Trial Court and the Court of Appeals erred in disregarding documentary evidence and deciding the case based solely on the credibility of witnesses and alleged procedural irregularities.
RULING
The Supreme Court granted the petition, reversing the lower courts. The legal logic is that while factual findings are generally binding, exceptions exist when there is a misapprehension of facts or a grave abuse of discretion in evidence appreciation. Here, the lower courts improperly ignored clear documentary evidence—duly signed delivery receipts and purchase orders—in favor of unsupported allegations about company procedure and irregularities. The respondent’s arguments were self-serving; non-compliance with internal procedure does not negate the existence of a transaction, especially when authorized personnel like Acuña, the maintenance manager, approved the orders. The Court found it illogical for petitioner to fabricate extensive documentation and pursue lengthy litigation for a non-existent obligation. Documentary evidence, when duly identified and established, must be given substantial weight alongside witness testimony. Consequently, respondent is liable for the unpaid supplies, with legal interest, attorney’s fees, and costs.