Ogawa v. Menigishi
REITERATIONFacts
The Antecedents: Petitioner Roseña Fontelar Ogawa and respondent Elizabeth Gache Menigishi, former childhood friends and residents of Sorsogon City, had a falling out over alleged financial transactions. Petitioner claimed respondent borrowed P15,000.00, P100,000.00, and P8,000.00 in September 2000, August 2001, and March 2003, respectively. When respondent could not repay, she allegedly offered to sell her building and its improvements in Sorsogon City to petitioner for P1,500,000.00, with the outstanding loans to be deducted from the purchase price and the balance payable in installments. Petitioner made partial payments totaling P400,772.90. However, respondent allegedly backed out of the sale. Procedural History: Petitioner filed a complaint for sum of money, damages, breach of good human relations, and unjust enrichment against respondent before the Regional Trial Court (RTC) of Sorsogon City, Branch 52. Respondent, in her Answer with Counterclaim, denied the indebtedness and claimed petitioner owed her 1,000,000.00 Yen, evidenced by a receipt. The RTC ruled in favor of petitioner, ordering respondent to pay P400,772.90 plus interest and damages. On appeal, the Court of Appeals (CA) affirmed the RTC's award of P400,772.90 to petitioner but granted respondent's counterclaim for 1,000,000.00 Yen, deleting the awards of damages and attorney's fees, finding both parties at fault. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision. The core issue presented to the Supreme Court is whether the disputed receipt sufficiently established respondent's counterclaim that petitioner owed her 1,000,000.00 Yen. Petitioner argued that the receipt was not a promissory note and its genuineness did not require a specific denial under oath, and denied any admission of liability from her counsel's manifestation. Respondent maintained that the CA did not err in sustaining the obligation based on the receipt, which petitioner allegedly never denied and her counsel implicitly admitted.
Issue(s)
Whether the disputed receipt sufficiently established respondent's counterclaim that petitioner owed her 1,000,000.00 Yen, and whether the CA erred in giving probative value to the receipt and holding petitioner indebted to respondent. Whether the CA erred in finding both parties at fault and deleting the damages awarded by the RTC.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision of the Court of Appeals, and reinstated the decision of the Regional Trial Court with modification. The respondent was ordered to pay the petitioner P400,772.00 plus 12% interest per annum from the date of filing until finality of the decision, and thereafter, 12% annual interest until fully paid.
Ratio Decidendi
On the sufficiency of the disputed receipt to establish respondent's counterclaim and the CA's error in giving it probative value: The Court found merit in the petition, holding that the CA erred in giving probative value to the receipt (Exhibit 1) for 1,000,000.00 Yen. While the receipt contained the signatures of both parties and acknowledged receipt of money, its plain text did not indicate the nature of the transaction or who between the parties was the obligor and obligee. The Court emphasized that a receipt is merely a written acknowledgment of delivery or receipt of money or goods. Without terms and conditions specifying the transaction, it cannot be considered an actionable document upon which a right or obligation may be founded. Therefore, it was not necessary for the adverse party to specifically deny its genuineness and due execution under oath. The Court also clarified that the manifestation of petitioner's counsel in open court, stating that the one who usually prepares the receipt is the obligor or the creditor, did not conclusively admit petitioner's liability to respondent. The Court reiterated the principle that the burden of proof lies with the party asserting a right, and in a counterclaim, the defendant must prove the existence of the claim by a preponderance of evidence. In this case, respondent failed to discharge this burden. On the CA's finding that both parties were at fault and deletion of damages: The Court disagreed with the CA's finding that both parties were at fault. Since the respondent failed to prove her counterclaim by a preponderance of evidence, the award of damages granted by the RTC in favor of the petitioner was reinstated. The Court modified the award of actual damages, ordering that the amount of P400,772.00, in the nature of a loan or forbearance of money, shall earn 12% interest per annum reckoned from the date of filing of the instant complaint until the finality of the decision. Thereafter, the judgment award inclusive of interest shall bear 12% annual interest until fully paid, citing Eastern Shipping Lines, Inc. v. Court of Appeals.
Main Doctrine
A mere written and signed acknowledgment that money was received, lacking terms and conditions, is not an actionable document and does not, by itself, establish a loan or indebtedness without further evidence.