Lazaro v. Brewmaster International
REITERATIONFacts
The Antecedents: Respondent Brewmaster International, Inc. filed a Complaint for Sum of Money against Prescillo G. Lazaro and petitioner Victorina Alice Lazaro for an unpaid obligation amounting to Php 138,502.92, incurred from February 2002 to May 2002 for beer and other products obtained on credit. The sales invoices attached to the complaint indicated that the purchaser was "TOTAL" and the items were received by Daniel Limuco. Procedural History: Prescillo and petitioner denied the obligation, asserting they had lived separately since January 15, 2002, and that petitioner never authorized any purchase. They also pointed out that the invoices showed "TOTAL" as the purchaser. Both defendants failed to appear at the preliminary conference, leading the Metropolitan Trial Court (MeTC) to declare the case submitted for decision. The MeTC dismissed the complaint, finding that the respondent failed to meet the burden of proof as the sales invoices did not show the goods were received by the defendants. The Regional Trial Court (RTC) affirmed the MeTC's decision, disallowing additional evidence presented by the respondent on appeal. The Court of Appeals (CA) reversed the RTC, holding that under the Revised Rule on Summary Procedure, judgment should be rendered based on the facts alleged in the complaint due to the defendants' failure to appear at the preliminary conference, and ordered the defendants to pay the amount claimed plus interest. The Petition: Petitioner seeks a review of the CA's decision, arguing that the CA erred in interpreting Section 6 of the Revised Rule on Summary Procedure and in granting relief despite the complaint allegedly failing to state a cause of action against her, as the sales invoices showed "TOTAL" as the purchaser.
Issue(s)
Whether the Court of Appeals erred in reversing the Regional Trial Court's decision based on Section 6 of the Revised Rule on Summary Procedure. Whether the complaint sufficiently states a cause of action against the petitioner.
Ruling
The Supreme Court affirmed the Decision of the Court of Appeals dated September 4, 2007, and its Resolution dated January 31, 2008. The Court ordered the petitioner and her husband to pay, jointly and severally, the amount of ₱138,502.92, plus legal interest.
Ratio Decidendi
On the first issue regarding the interpretation of Section 6 of the Revised Rule on Summary Procedure: The Court held that the CA correctly applied Section 6 and Section 7 of the Revised Rule on Summary Procedure. The rule mandates that judgment should be rendered "as may be warranted by the facts alleged in the complaint" when defendants fail to appear at the preliminary conference. This provision aims to avoid delay and considers non-appearance as an admission of the ultimate facts. The MeTC's focus on the sales invoices, which are evidentiary in nature, instead of the ultimate facts alleged in the complaint, contravened the purpose of the rule. The CA's pronouncement that evidentiary matters are to be considered only upon termination of the preliminary conference if further proceedings are necessary is consistent with Section 9 of the same rule. Therefore, the CA did not err in reversing the trial court's decision based on the allegations in the complaint, given the defendants' failure to appear. On the second issue regarding the sufficiency of the cause of action: The Court found that the complaint sufficiently stated a cause of action for collection of a sum of money. The complaint alleged that the petitioner and her husband obtained goods on credit from the respondent worth ₱138,502.92 and failed to pay despite repeated demands. These allegations constitute the essential elements of a cause of action. The Court clarified that while all documents attached to the complaint may be considered to ascertain sufficiency, the inquiry is into the sufficiency, not the veracity, of the allegations. The sales invoices, even if naming "TOTAL" as the purchaser, do not absolutely preclude the petitioner's liability. Such invoices are merely detailed statements of goods sold and their cost, not conclusive proof of the extent of involvement or liability. The Court cited Peña v. Court of Appeals to emphasize that facts in sales invoices may be explained and contradicted by other facts and circumstances, and that oral testimony could have established the petitioner's link to the transactions had the case proceeded further.
Main Doctrine
Under the Revised Rule on Summary Procedure, failure to appear at the preliminary conference may be considered an admission of the ultimate facts alleged in the complaint, warranting judgment based on those allegations, provided the complaint sufficiently states a cause of action.