Eugenio v. Pepsi-Cola Bottling Company of the Philippines, Inc.
REITERATIONFacts
The Antecedents: Petitioners Nora S. Eugenio and Alfredo Y. Eugenio were a dealer and former route manager, respectively, of private respondent Pepsi-Cola Bottling Company of the Philippines, Inc. Private respondent filed a complaint for a sum of money, alleging an outstanding balance of P94,651.00 for products purchased on credit and loaned empties. Procedural History: The Regional Trial Court (RTC) initially ordered petitioners to pay P74,849.00 plus interest and attorney's fees. The Court of Appeals (CA) declared this decision a nullity for failing to comply with constitutional requirements and remanded the case. The RTC rendered a second decision ordering payment of P64,188.60 plus legal interest, which the CA affirmed. Petitioners appealed to the Supreme Court. The Petition: Petitioners contended that four trade provisional receipts (TPRs) totaling P80,560.00 should have been credited to their account. They also claimed that Nora S. Eugenio's signature on Sales Invoice No. 85366 was falsified. They argued that if these amounts were credited, Pepsi-Cola would be indebted to them.
Issue(s)
Whether the trade provisional receipts (TPRs) presented by the petitioners should be credited to their account. Whether the signature of petitioner Nora S. Eugenio on Sales Invoice No. 85366 is falsified. Whether the respondent corporation sufficiently proved the outstanding account of the petitioners.
Ruling
The Supreme Court annulled and set aside the decision of the Court of Appeals and the trial court. It ordered private respondent Pepsi-Cola Bottling Company of the Philippines, Inc. to pay petitioners Nora and Alfredo Eugenio the amount of P5,710.60 representing overpayment.
Ratio Decidendi
On whether the trade provisional receipts (TPRs) should be credited: The Court found that the respondent corporation failed to discharge the burden of proof. The testimony of Jovencio Estrada, who allegedly denied issuing the TPRs, was hearsay as Estrada was not presented as a witness. His affidavit was also inadmissible hearsay. Furthermore, the respondent corporation failed to present any specimen of Estrada's signature for comparison, despite the importance of verifying the authenticity of the TPRs. The Court also noted that payments made to an authorized agent, like Estrada, extinguish the obligation of the customer. The TPRs are disputably presumed to be evidence of payment, and the respondent failed to rebut this presumption. On the alleged falsification of Sales Invoice No. 85366: The Court noted that the amount of P5,631.00 from Sales Invoice No. 85366 had already been deducted from the petitioners' liability during the reconciliation meeting, as confirmed by the reconciliation sheet. Therefore, this amount should not have been included in the final computation of the debt. On whether the respondent corporation sufficiently proved the outstanding account: The Court concluded that the respondent corporation failed to comply with the rules for the admission of evidence. The reliance on hearsay testimony and the failure to present crucial witnesses and authenticated documents meant that the respondent did not discharge the requisite quantum of evidence to prove its claim. The Court found that after crediting the TPRs and considering the already deducted amount from the disputed invoice, the petitioners had actually overpaid the respondent by P5,710.60.
Main Doctrine
The Supreme Court held that the respondent corporation failed to discharge the burden of preponderant proof to establish the petitioners' outstanding account due to inadmissible hearsay evidence and failure to present crucial witnesses. The Court also affirmed that payment made to an authorized agent extinguishes the obligation, and that trade provisional receipts, when presented, are disputably presumed to be evidence of payment.