Pilar Development Corporation v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Petitioner Pilar Development Corporation (PDC) purchased 3,000 bags of cement from respondent Kingswood Trading Co., Inc. (Kingswood) for use in its housing and subdivision development projects. PDC alleged that the cement delivered was defective, causing it to stop operations, demolish constructions, and incur damages. Kingswood denied liability, claiming it was merely a dealer and not a manufacturer, and filed a third-party complaint against Construction and Development Corporation of the Philippines (CDCP), the alleged manufacturer. Procedural History: The trial court dismissed PDC's complaint, Kingswood's third-party complaint, and the counterclaims, finding that PDC failed to establish by preponderance of evidence that the defective concrete mix was caused by the cement delivered by Kingswood. The trial court noted the possibility of other cement brands being used and the lack of personal knowledge from witnesses regarding the use of the questioned cement. The Intermediate Appellate Court (IAC) affirmed the trial court's decision, also finding that PDC failed to establish a preponderance of evidence and ordering the return of the invoice value of the unused cement. The Petition: PDC filed a Petition for Review with the Supreme Court, alleging that the IAC committed errors of law in its failure to draw the correct conclusion from the undisputed factual findings.
Issue(s)
Whether the Intermediate Appellate Court committed errors of law in its failure to draw the correct conclusion from its undisputed factual findings. Whether the plaintiff-appellant established by preponderance of evidence that the defective concrete mix was caused by the cement delivered by the defendant-appellee. Whether the plaintiff-appellant is entitled to the replacement of the 809 bags of Midland Cement.
Ruling
The Supreme Court denied the Petition for Review for lack of merit, affirming the decision of the Intermediate Appellate Court. However, it ordered the private respondent (Kingswood) to return the invoice value (P11,326) of the 809 bags of cement returned by the petitioner.
Ratio Decidendi
On the alleged errors of law and failure to draw correct conclusions from undisputed facts: The Supreme Court reiterated that while a question of law arises when the doubt is as to what the law is on a certain state of facts, a question of fact arises when the doubt is as to the truth or falsehood of alleged facts. The Court found that the petitioner's contention raised more of a question of fact than a question of law, as it involved the evaluation of evidence to determine the cause of the defective concrete mix. The Court emphasized that the law creating the Court of Appeals was intended to relieve the Supreme Court of the work of examining evidence, confining its task to questions not requiring the reading of transcripts. Therefore, the Supreme Court found no compelling reason to disagree with the findings and conclusions of the respondent court. On the failure to establish by preponderance of evidence that the defective concrete mix was caused by the cement: The Court applied the rule on the burden of proof, stating that where the evidence on an issue of fact is in equipoise or there is doubt on which evidence preponderates, the party with the burden of proof must fail. The Court found that the plaintiff (petitioner herein) failed to establish by a preponderance of evidence that the defective concrete mix was caused by the Midland Cement delivered by Kingswood. The Court noted that the trial court found a probability that the defect was not caused by the questioned cement, especially since another brand of cement was delivered on the same day. The evidence presented by both parties regarding the quality of the cement was considered to be in equipoise, thus the plaintiff, who had the burden of proof, failed to discharge it. On the return of the 809 bags of Midland Cement: The Court noted that the trial court had ordered the return of the sum of P11,326.00, which was the invoice value of the 809 bags of Midland Cement. Considering that the petitioner was the one who actually returned the bags to the defendant-appellee, the Court found this to be the most equitable remedy and affirmed the trial court's order in this regard.
Main Doctrine
Where the evidence on an issue of fact is in equipoise or there is any doubt on which the evidence preponderates, the party having the burden of proof falls upon that issue. If the evidence touching a disputed fact is equally balanced, or if it does not produce a just, rational belief of its existence, or if it leaves the mind in a state of perplexity, the party holding the affirmative as to such fact must fail.