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TERESITA B. MENDOZA v. BETH DAVID

FACTS:

This case involves a petition for review of the Decision and Resolution of the Court of Appeals. The petitioner, Teresita B. Mendoza, filed an action for collection of money with damages against the respondent, Beth David, before the Metropolitan Trial Court (MTC) of Quezon City. Mendoza alleged that she ordered three sets of furniture from David but rejected them due to inferior material and poor quality. Mendoza demanded a refund of her deposit, but David refused. The MTC dismissed Mendoza's complaint, finding that there was a perfected contract of sale. Mendoza appealed to the Regional Trial Court (RTC), which agreed with the MTC's decision but reduced the balance owed by Mendoza. Mendoza filed a petition for review with the Court of Appeals, which dismissed it for being insufficient in form and substance. Mendoza filed a motion for reconsideration, which was denied.

ISSUES:

  1. Whether the petitioner's failure to comply with the formal requirements of the petition, particularly in not attaching the necessary pleadings and documents, warrants dismissal of the petition.

  2. Whether the Court of Appeals erred in relying on the doctrine that factual findings of the lower courts are entitled to great weight despite the absence of the necessary records.

RULING:

  1. The failure of the petitioner to comply with the formal requirements of the petition does not automatically warrant dismissal of the petition. The rules of procedure should be liberally construed in order to promote their objective of securing a just, speedy, and inexpensive disposition of every action and proceeding. In cases where the appellant had substantially complied with the formal requirements, the Court has ruled against dismissal based solely on technicalities. Subsequent filing or submission of the missing documents with a motion for reconsideration amounts to substantial compliance, thereby justifying relaxation of the rules of procedure.

  2. The Court of Appeals erred in relying on the doctrine that factual findings of the lower courts are entitled to great weight without the necessary records to determine whether substantial evidence supports the findings. Instead, the Court of Appeals should have required the petitioner to submit additional documents in line with the rules, or order the Clerk of the Regional Trial Court to elevate the original records for a complete adjudication of the case.

PRINCIPLES:

  • Rules of procedure should be used to promote justice, not frustrate it.

  • Failure to comply with the formal requirements of a petition does not automatically warrant dismissal if there is substantial compliance and subsequent submission of the missing documents.

  • Factual findings of the lower courts are entitled to great weight if supported by substantial evidence in the records.

  • The doctrine of relying on factual findings should not be applied if there is an absence of necessary records. The court may require the submission of additional documents or elevate the original records for a complete adjudication of the case.

  • Whether a transaction is a sale by sample, a sale by description, or "made to order" is a question of fact for the trial court to decide.

  • In a sale by sample, there is an implied warranty that the goods shall be free from any defect not apparent on reasonable examination of the sample and which would render the goods unmerchantable.

  • In a sale of goods by description, there is an implied warranty that the goods will conform to that description.

  • The burden of proof rests on the party who asserts the affirmative of an issue based on the pleadings or the nature of the case.