Francisco v. Mandi
REITERATIONFacts
The Antecedents: Petitioner Mateo P. Francisco borrowed P3,000.00 from private respondent Albino Arevalo in November 1974. To secure this loan, private respondent mortgaged a parcel of agricultural land with the Philippine National Bank (PNB) for P3,000.00 on November 20, 1974. Petitioner and his wife signed as principal co-obligors on the Real Estate Mortgage, and petitioner, his wife, and private respondent (along with his late wife) signed a promissory note in favor of PNB. The understanding was that petitioner would assume and pay the obligation plus interest. Petitioner personally received the P8,000.00 loan proceeds from PNB. In a letter dated August 5, 1976, petitioner admitted his loan account of P8,000.00 with PNB. Procedural History: When the loan became due, private respondent paid it to prevent foreclosure. Petitioner failed to reimburse private respondent. On July 14, 1980, private respondent filed a complaint for recovery of money against petitioner. Petitioner denied the allegations, claiming he and his wife accommodated private respondent, and that he made payments to the bank on behalf of private respondent. The trial court ruled in favor of private respondent, ordering petitioner to pay P8,591.55 plus legal interest and P1,500.00 as attorney's fees and costs. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a petition for review on certiorari, seeking to annul the decision and order of the trial court, arguing that the court erred or abused its discretion in holding that he received the loan proceeds, as no documentary evidence was adduced by private respondent to show this, and bank policy dictates proceeds are delivered to the borrower unless written authority is given.
Issue(s)
Whether certiorari will lie against the trial court's decision. Whether the trial court erred or abused its discretion in holding that petitioner received the proceeds of the loan.
Ruling
The petition is dismissed, and the assailed decision and order are affirmed.
Ratio Decidendi
On the issue of whether certiorari will lie: The Court reiterated the established rule that for certiorari to lie, there must be a capricious, arbitrary, and whimsical exercise of power, which is the very antithesis of judicial prerogative. The abuse of discretion must be grave and patent, and it must be shown that the discretion was exercised arbitrarily or despotically. In the instant case, the Court found no such capricious, arbitrary, or whimsical exercise of power by the respondent judge. The petitioner's averments regarding the best evidence and bank policy were addressed by the trial court's findings, which were supported by evidence. On the issue of whether the trial court erred or abused its discretion in holding that petitioner received the loan proceeds: The Court found no error or abuse of discretion. The petitioner himself pointed out an exception to the general rule: "unless of course a written authority was given by plaintiff to defendant." The respondent Judge, in denying the motion for reconsideration, pointed to Exhibit B, the Promissory Note dated November 22, 1974, which acknowledged receipt of P8,000.00 and was signed by both parties and their respective spouses. Crucially, the phrase "please pay the proceed of this loan to Mr. Mateo P. Francisco" was typewritten at the bottom of Exhibit B. Furthermore, the petitioner's own testimony that he received all the proceeds of the loan was not controverted during the trial. The Court also emphasized that petitioner's own letter (Exhibit C), addressed to the PNB Manager on August 5, 1976, categorically admitted that the P8,000.00 loan was his account. This admission is admissible evidence against him. Therefore, the findings of fact of the trial court, being supported by substantial and unrefuted oral and documentary evidence, are binding on the Supreme Court, and the Court will not substitute its judgment for that of the trial court on matters of evidence.
Main Doctrine
Certiorari will not lie absent a capricious, arbitrary, and whimsical exercise of power, which must be grave and patent. The Supreme Court will not substitute its judgment for that of the trial court on matters involving the weight of evidence, especially when the trial court's findings are supported by substantial evidence.