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VICTORINA ALICE LIM LAZARO v. BREWMASTER INTERNATIONAL

FACTS:

Respondent Brewmaster International, Inc. filed a Complaint for Sum of Money against Prescillo G. Lazaro and petitioner Victorina Alice Lazaro. The complaint alleged that the defendants obtained goods from the plaintiff on credit but failed to fulfill their obligation to pay. Sales invoices attached to the complaint indicated that the goods were sold to "TOTAL" and received by a certain Daniel Limuco.

Prescillo and petitioner filed separate answers denying any knowledge of the obligation and claiming that Total should be the one sued. During the preliminary conference, both defendants failed to appear, prompting the Metropolitan Trial Court (MeTC) to declare the case submitted for decision. Eventually, the MeTC dismissed the complaint, ruling that the plaintiff failed to meet the burden of proof.

The Regional Trial Court (RTC) affirmed the decision of the MeTC. However, the Court of Appeals (CA) reversed the ruling and held that judgment should have been rendered in favor of the plaintiff. The CA emphasized that judgment should be based on the allegations of the complaint, not on the evidence submitted.

ISSUES:

  1. Whether the MeTC erred in dismissing the complaint due to respondent's failure to meet the burden of proof.

  2. Whether the MeTC was correct in disregarding the documents attached to the memorandum as additional evidence.

  3. Whether the CA erred in reinstating the complaint and awarding judgment in favor of respondent.

RULING:

  1. The MeTC did not err in dismissing the complaint. The sales invoices attached to the complaint showed that the goods were sold to Total and were received by a certain Daniel Limuco, and not by the petitioner or her husband. Respondent failed to provide significant evidence to establish that petitioner and her husband were liable for the obligation.

  2. The MeTC was correct in disregarding the documents attached to the memorandum as additional evidence. The admission of such evidence would violate the basic rule of fair play and the other party's right to due process.

  3. The CA erred in reinstating the complaint and awarding judgment in favor of respondent. The MeTC judgment dismissing the complaint was proper based on the lack of evidence presented by respondent.

PRINCIPLES:

  • Burden of proof requires a party to prove a disputed fact by preponderance of evidence.

  • Additional evidence submitted on appeal should be disregarded as it would violate the other party's right to due process.

  • Judgment in summary procedure cases should be based on the allegations of the complaint.