De Guzman v. CA

G.R. No. 110122 (August 7, 1996)

Facts:

This case involves a dispute between Celestina G. De Guzman (petitioner) and spouses Cresenciano and Lucila De Guzman-Sioson (respondents) regarding a debt of P92,000. The respondents filed a complaint against the petitioner, claiming that she owed them this amount. The basis of their claim was a letter allegedly written by the petitioner, which stated her willingness to pay P92,000 and requested forgiveness for past shortcomings due to her health condition following a stroke.

The petitioner denied the debt, asserting that the letter was a forgery. The relationship between the parties is familial, as the petitioner is the widow of Lucila's elder brother, Andres De Guzman. The respondents contended that the petitioner managed a riceland owned jointly by them and the deceased husband of the petitioner, and that she failed to deliver Lucila's share of the harvest. Cresenciano had previously demanded the delivery of 1,500 cavans of palay from the petitioner, but after receiving the letter, he initially rejected the offer of P92,000. However, due to financial difficulties, he later agreed to the amount, but the petitioner did not fulfill her promise to pay.

After the petitioner failed to respond to a demand letter from the respondents' lawyer, they initiated legal action in the Regional Trial Court (RTC) of Cabanatuan City. The RTC ruled in favor of the respondents, ordering the petitioner to pay the claimed amount plus interest and attorney's fees. The petitioner appealed to the Court of Appeals, which affirmed the RTC's decision.

Legal Issues:

1. Whether the trial court erred in giving credence to the respondents' testimony regarding the acknowledgment of the debt by the petitioner as evidenced by the letter (Exhibit C).
2. Whether the trial court erred in admitting a photocopy of the letter as evidence despite the original being lost.
3. Whether the trial court erred in not dismissing the case and in not granting damages to the petitioner for what she claimed was a malicious and vindictive lawsuit.

Arguments:

• Petitioner's Arguments:

  • The petitioner argued that she was not indebted to the respondents and that the letter was a forgery.
  • She claimed that she was not the manager of the riceland and had never sent the letter in question.
  • The petitioner contended that the trial court erred in admitting the photocopy of the letter as evidence, as the original was lost under questionable circumstances.
  • She also argued that the delay in filing the case indicated a lack of urgency and legitimacy in the respondents' claims.

• Respondents' Arguments:

  • The respondents maintained that the letter was genuine and constituted an acknowledgment of the debt.
  • They argued that the loss of the original letter was adequately explained and that the photocopy was admissible as secondary evidence.
  • The respondents emphasized that their delay in filing the case was due to negotiations for an amicable settlement, which should not be held against them.

Court's Decision and Legal Reasoning:

The Supreme Court denied the petition for review and affirmed the decision of the Court of Appeals. The Court held that it is not its function to re-evaluate the evidence presented in the lower courts, especially when the factual findings of the trial court are affirmed by the appellate court. The Court found that the trial court correctly accorded credence to the respondents' claims, noting that the petitioner's testimony was inconsistent and lacked credibility.

The Court also ruled that the admission of the photocopy of the letter was proper, as the original was lost, and the execution of the document was proven during the trial. The Court cited the rule that if the original document is lost, its contents may be proven by a copy or by the recollection of a witness, provided that the execution and loss are established.

Furthermore, the Court noted that the petitioner's defense was primarily based on denial, which is considered weak and self-serving in the absence of clear and convincing evidence to support it. The Court emphasized the importance of amicable settlements and found no error in the respondents' decision to delay filing the case while attempting to resolve the matter informally.

Significant Legal Principles Established:

1. The principle that denial, if unsubstantiated, is considered weak evidence and cannot outweigh credible testimony.
2. The admissibility of secondary evidence, such as a photocopy, when the original document is lost, provided that the execution and loss are proven.
3. The encouragement of amicable settlements in disputes, which may justify delays in filing legal actions.