BA FINANCE CORPORATION v. CA

FACTS:

Private respondents Manuel Cuady and Lilia Cuady obtained a credit from Supercars, Inc. for the purchase of a Ford Escort 1300 sedan. They executed a promissory note and a chattel mortgage to secure their payment obligations. The promissory note was assigned to petitioner B.A. Finance Corporation. The Cuadys made partial payments, leaving an unpaid balance of P2,344.65, as well as penalties for late payments. B.A. Finance Corporation renewed the insurance coverage of the motor vehicle with Zenith Insurance Corporation. The vehicle was involved in an accident in April 1980 and the Cuadys requested B.A. Finance Corporation to claim from the insurer and apply it to their remaining account. However, B.A. Finance Corporation insisted on having the vehicle repaired. The vehicle then broke down and the Cuadys requested B.A. Finance Corporation again to enforce the total loss provision in the insurance coverage, but B.A. Finance Corporation did not respond favorably. As a result, the Cuadys stopped paying their monthly installments. B.A. Finance Corporation then filed a lawsuit against the Cuadys for the recovery of the remaining installments. During the trial, B.A. Finance Corporation's motion for postponement was denied, and the court allowed the Cuadys to present evidence ex-parte in the form of an affidavit. B.A. Finance Corporation's motion for reconsideration was granted, allowing them to submit counter-affidavits, but they failed to comply. As a result, the trial court dismissed the complaint, which was affirmed by the Court of Appeals. B.A. Finance Corporation's motion for reconsideration was also denied. This petition for review on certiorari seeks to reverse the decisions of the lower courts.

ISSUES:

  1. Whether or not B.A. Finance Corporation is entitled to recover the remaining installments from the Cuady spouses.

  2. Whether or not the trial court erred in denying B.A. Finance Corporation's motion for postponement.

RULING:

  1. The Supreme Court ruled that B.A. Finance Corporation is entitled to recover the remaining installments from the Cuady spouses. The Court held that the Cuady spouses' failure to pay the remaining installments on the promissory note constituted a breach of their contractual obligation. As a result, B.A. Finance Corporation is entitled to recover the remaining balance and penalties from the Cuady spouses.

  2. The Supreme Court held that the trial court did not err in denying B.A. Finance Corporation's motion for postponement. The Court explained that the denial was justified as the 'handling' counsel of B.A. Finance Corporation was temporarily assigned in another city and could not attend the hearing. Moreover, the Court noted that the trial court did allow the Cuady spouses to present evidence ex-parte through an affidavit, thereby giving B.A. Finance Corporation an opportunity to present counter-affidavits.

PRINCIPLES:

  • Failure to pay the remaining installments on a promissory note constitutes a breach of a contractual obligation.

  • A trial court's denial of a motion for postponement is justified when there is a valid reason and the opposing party is given an opportunity to present evidence.