Espino v. Amora
REITERATIONFacts
The Antecedents: Respondents Normandy and Nelia Amora, doing business as NBA Enterprises, supplied construction materials on credit to D.N. Tuangco Construction and Development Corporation and CEJ Construction, owned by the family of petitioner Violeta Espino, since 1994. Espino's total purchases amounted to P1,992,839.64. Although Espino remitted P2,085,000.00, respondents claimed an outstanding balance of P916,208.77 as of October 15, 1997, inclusive of 3% monthly interest. Respondents filed a complaint for sum of money and damages. Procedural History: Espino claimed full payment and denied agreeing to the 3% monthly interest, asserting the delivery receipt stipulated only 12% per annum. Espino failed to file a pre-trial brief or appear at the pre-trial hearing, leading the trial court to allow respondents to present evidence ex-parte. The RTC rendered a decision ordering Espino to pay P1,109,716.94 plus 25% attorney's fees. The RTC later reconsidered and deducted P65,000.00 from the award. On appeal, the Court of Appeals (CA) affirmed the subsisting obligation and interest but reduced the interest rate to 12% per annum and attorney's fees to 10%. Espino filed a motion for clarification and reconsideration, which was denied. The Petition: Espino filed a petition for review on certiorari with the Supreme Court, questioning the CA's affirmation of her outstanding obligation despite remittances and the base amount for applying the 12% interest rate.
Issue(s)
Whether the CA erred in sustaining Espino's outstanding obligation to NBA Enterprises notwithstanding the P2,085,000.00 already remitted. Whether Espino's outstanding obligation pegged at P1,044,716.64 by the RTC is the correct base for applying the twelve percent (12%) reduced rate of interest imposed by the CA.
Ruling
The petition is bereft of merit. The Supreme Court denied the petition, ordering Violeta Espino to pay Normandy P. Amora and Nelia B. Amora, doing business as NBA Enterprises, P818,342.56 plus 12% per annum interest from judicial demand on November 10, 1997, legal interest of 12% per annum on the total amount due from finality of the decision until fully paid, 10% of the amount due as attorney's fees, and costs of suit.
Ratio Decidendi
On the issue of sustaining Espino's outstanding obligation: The Court upheld the findings of the RTC and CA that Espino has an outstanding obligation. The Court reiterated the rule that factual findings of the trial court, especially when affirmed by the appellate court, are accorded the highest degree of respect and are considered conclusive between the parties, unless exceptions apply. None of the exceptions were found to be present. The Court found Espino's computation simplistic, noting that the established arrangement involved a continuing credit line with a 3% monthly interest on the remaining balance. Espino had consistently acquiesced to this arrangement from 1994, even certifying as correct statements of account and acknowledging her liability in a Deed of Assignment and an Affidavit. Her belated challenge to the computation and interest imposition was deemed unavailing given her prior unequivocal acquiescence. The Court also noted that installment payments were applied to diminish the outstanding obligation and continue the credit arrangement, not solely for the principal amount of purchases. On the issue of the correct base for applying the reduced interest rate: The Court clarified the computation of Espino's outstanding obligation. While Espino acknowledged an obligation of P977,215.46 as of July 1996, which she acknowledged on three separate occasions, her subsequent refutation of the 3% monthly interest rate in March 1997, claiming only P245,239.64, was unsubstantiated. The Court noted that NBA Enterprises reduced its demand to P818,342.56 by June 1997, deducting some payments. The Court found that the evidence presented ex-parte by NBA Enterprises showed Espino's indebtedness at the time of the complaint's filing was P818,342.56. Therefore, this amount was deemed the correct base for applying the 12% per annum interest rate from the date of judicial demand (November 10, 1997), as affirmed by the CA. The Court also sustained the CA's reduction of attorney's fees to 10% and the imposition of legal interest from finality of the decision.
Main Doctrine
A party who has consistently acknowledged and benefited from a credit arrangement, including the imposition of interest rates, cannot later dispute the computation of her outstanding obligation, especially when such dispute is belated and unsubstantiated.