Cuyugan v. Siasoco
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns an alleged unpaid obligation for election campaign materials. The petitioner, owner of a printing press named CPAAA Prints, claimed that the respondent, a candidate for vice mayor, ordered various campaign materials totaling P212,890.00. The respondent admitted ordering materials but asserted that his obligations had been settled, and any remaining unpaid amounts were for materials ordered by other candidates for whom he was not responsible. 2. Procedural History: The petitioner filed a Complaint for Sum of Money with Attachment against the respondent before the Regional Trial Court (RTC) of Marikina City. After a pre-trial conference where certain facts were stipulated, the RTC rendered a decision in favor of the petitioner, ordering the respondent to pay P183,210.00 plus interest and attorney's fees. The respondent appealed this decision to the Court of Appeals (CA). The CA modified the RTC's decision, reducing the respondent's liability to P20,945.00 plus interest, finding that the respondent was only liable for the materials he personally ordered and received, not those intended for other candidates. 3. The Petition: The petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to reverse the CA's decision. The petitioner argued that the respondent was liable for the campaign materials of other candidates, citing a stipulation during pre-trial that the petitioner's printing press was a source of materials for the respondent and his party mates. The petitioner contended that this stipulation obviated the need for further proof of the respondent's liability for these other materials. The core of the petition is the petitioner's assertion that the respondent should be held accountable for the campaign materials ordered by his fellow candidates.
Issue(s)
Whether the respondent is liable for the campaign materials of other candidates belonging to his party. Whether the petitioner presented sufficient evidence to establish the respondent's claim regarding the other candidates' materials. Whether a stipulation made during pre-trial obviated the need for such evidence.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. The respondent is liable for the remaining unpaid obligation of ₱20,945.00.
Ratio Decidendi
On the issue of respondent's liability for campaign materials of other candidates: The Court found that the petitioner failed to substantiate his claim that the respondent ordered and received the campaign materials for his partymates. The evidence presented, consisting of an unsigned Sales Invoice and delivery receipts, was insufficient. Only two out of twenty-two delivery receipts were acknowledged by individuals not proven to be representatives of the respondent. The petitioner's own testimony admitted uncertainty about whether the personnel picking up the materials were employees of the respondent, and that most delivery receipts were unacknowledged because he was not present in his office. The Court adopted the CA's finding that there was no basis to hold Siasoco liable for materials ordered by his party-mates. On the sufficiency of petitioner's evidence: The Court reiterated the rule that it does not resolve factual questions in an appeal by certiorari, but made an exception due to the conflicting findings of the RTC and CA. The Court found the petitioner's evidence insufficient. The petitioner failed to present proof of actual receipt of the materials by the respondent or his authorized representative. The claim that a staff member named 'Nora' placed orders was unsubstantiated, as there was no proof that Nora was an agent or employee of the respondent, nor was there corroboration that respondent confirmed these orders. The testimony of the campaign operations manager did not confirm placing orders with the petitioner. On the effect of the stipulation of facts during pre-trial: The Court disagreed with the petitioner's interpretation of the stipulation. The stipulation stated: "That the plaintiff (petitioner) was one of the sources of the election materials by the defendant (respondent) inclusive of all the party mates running." The Court held that this stipulation only admitted that the petitioner was one of the sources of election materials for the respondent and his partymates, not that the respondent was solely responsible for all materials obtained from the petitioner. Applying the plain meaning rule, the stipulation did not contain qualifying words that would extend the respondent's liability beyond what was literally stated. The Court noted that if the respondent had judicially admitted liability, a full trial would have been unnecessary, and a summary judgment could have been rendered, which did not happen. The respondent consistently denied liability for other candidates' accounts in his pleadings.
Main Doctrine
The petitioner failed to discharge the burden of proof to establish by preponderance of evidence that the respondent ordered and received campaign materials intended for other candidates, and the stipulation of facts during pre-trial did not constitute an admission of liability for such materials.