Towne & City Development Corporation v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondent Guillermo Voluntad and petitioner Towne & City Development Corporation, both engaged in construction, entered into a contract from 1984 to 1985 for the construction and repair of housing units and facilities at the petitioner's Virginia Valley Subdivision. The total contract cost was P1,041,359.00, with payment due in full upon completion. Guillermo was allowed to occupy one of the houses rent-free pending completion. After completing the work, Guillermo demanded payment, alleging a remaining balance of P971,959.00 after petitioner paid only P69,400.00. Procedural History: Guillermo filed a collection complaint against petitioner on April 30, 1990, before the Regional Trial Court (RTC) of Manila. Petitioner countered, claiming full payment of P1,022,793.46 and an overpayment of P58,189.46, plus P66,000.00 in unpaid rentals for Guillermo's occupancy. During the proceedings, Guillermo passed away and was substituted by his heirs. The RTC, on December 29, 1994, ordered petitioner to pay Guillermo's heirs P715,228.50 with interest and ordered Guillermo's heirs to vacate the occupied house. Petitioner's motion for reconsideration was denied. Petitioner partially appealed to the Court of Appeals (CA) regarding the unpaid balance. On August 12, 1998, the CA affirmed the RTC decision. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. Petitioner argued that the CA erred in not considering its vouchers and other documentary exhibits as proof of payment and in ignoring the ruling in Philippine National Bank vs. Court of Appeals. The Supreme Court, however, found that these arguments raised questions of fact, which are generally not reviewable under Rule 45, especially when affirmed by both the trial court and the appellate court. The Court emphasized that it is not a trier of facts and that the distinction between vouchers and receipts, as well as the credibility of witnesses, are factual matters. The Court ultimately denied the petition, affirming the CA's decision.
Issue(s)
Whether the Court of Appeals committed reversible errors of law or acted with grave abuse of discretion in not considering the vouchers and other documentary exhibits as proofs of payment. Whether the issue of whether a voucher suffices as evidence of payment is a question of law.
Ruling
The Petition is DENIED. The Decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the issue of whether the Court of Appeals committed reversible errors of law or acted with grave abuse of discretion in not considering the vouchers and other documentary exhibits as proofs of payment: The Court held that the alleged errors raised by the petitioner pertain to the appreciation of evidence, which are questions of fact. As a rule, a petition for review under Rule 45 of the Rules of Civil Procedure should raise only questions of law. The findings of fact of the trial court, when affirmed by the Court of Appeals, are binding upon the Supreme Court, unless they fall under recognized exceptions, none of which were present in this case. The Court emphasized that it is not a trier of facts. The Court further clarified that vouchers are not receipts and are not necessarily evidence of payment. They are merely internal records of disbursement. Unless supported by actual payment like an encashed check or a duly receipted cash payment, a voucher has no evidentiary weight. The Court distinguished vouchers from receipts, noting that a receipt is a written acknowledgment of payment, while a voucher is a record of a transaction. The references to alleged check payments in the vouchers did not convert them into receipts. Under Article 1249 of the Civil Code, payment by check produces the effect of payment only when cashed or when impaired through the creditor's fault, neither of which was proven. The Court also found no sufficient rebuttal evidence to overturn the trial court's findings, which were upheld by the appellate court. On the issue of whether the issue of whether a voucher suffices as evidence of payment is a question of law: The Court ruled that the question of whether petitioner's vouchers constitute adequate proof of payment requires an examination of the vouchers and the circumstances surrounding their issuance, which are functions reserved for the trial courts and the Court of Appeals in reviewing findings of fact. Therefore, it is a question of fact, not a question of law, and thus not properly cognizable in a petition for review under Rule 45. The Court reiterated that while a receipt is the best evidence of payment, it is not conclusive and can be rebutted by parole evidence. However, the petitioner's reliance on vouchers, which are distinct from receipts, was found insufficient to prove payment.
Main Doctrine
Vouchers, without supporting evidence of actual payment such as encashed checks or duly receipted cash payments, do not constitute sufficient proof of payment for an obligation. A receipt, while considered best evidence of payment, is not conclusive and can be rebutted by other evidence, but vouchers are merely internal records of disbursement and not evidence of payment in themselves.