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JurisprudenceG.R. No. 255264 -

G.R. No. 255264 - MANUEL ONG, VS. SPOUSES ROWELITO AND AMELITA VILLORENTE.

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TL;DR — Ruling

The petition is meritorious.

Decision

Ruling

accordingly, ordered respondents to pay the former the amounts of: ( a ) P420,000.00 plus twelve percent (12%) interest from extra-judicial demand on March 17, 2004 up to October 2013 and six percent (6%) legal interest from October 2013 until fully paid; ( b ) P50,000.00 as attorney's fees; ( c ) P1,000.00 as Sheriff's fees; and ( d ) P1,715.00 as cost of suit. [29] In so ruling, the RTC ruled that petitioner has proven his claim by preponderance of evidence. Respondents committed an act or omission in violation of petitioner's right when they failed to provide payment for the purchase of assorted textiles and clothing materials. Further, respondents failed to provide evidence to support their claim that they have already settled their obligations to petitioner. On the contrary, the sale transaction between petitioner and respondents was supported by the promissory notes signed by respondents. [30] Dissatisfied, respondents appealed to the CA. The CA Ruling In a Decision [31] dated December 5, 2019, the CA reversed and set aside the RTC ruling, and accordingly, dismissed petitioner's complaint for lack of merit. [32] According to the CA, the complaint failed to establish a prima facie case tending to show the existence of a perfected contract of sale. The CA ruled that the dishonored checks are not competent proof to establish the fact that these were issued for payment of the purchases from 1991 to 1993. Likewise, the submitted promissory notes were held insufficient to indicate the specific obligation or transaction which it referred to. As such, petitioner failed to substantiate in his complaint a perfected contract of sale. Without proving the sale transaction, respondents cannot be held liable. [33] Petitioner moved for reconsideration, [34] which was denied in a Resolution [35] dated January 15, 2021; hence, this petition. [36] The Issue Before the Court The essential issue before the Court is whether or not the CA correctly reversed the RTC ruling, and accordingly, ruled that respondents' liability against petitioner was not established. The Court's Ruling The petition is meritorious. Preliminarily, it must be emphasized that as a general rule, only questions of law may be raised in a petition for review on certiorari under Rule 45 of the Rules of Court. The Court is not a trier of facts. Thus, it is not its function to reevaluate the probative value of the evidence of both parties, which were already considered in the proceedings below. [37] However, jurisprudence has provided certain exceptions to the above general rule, such as when the findings of the RTC on the one hand, and the CA, on the other are conflicting, as in this case. Thus, there is a need to reevaluate the factual issues and to reexamine the questioned findings. [38] In civil cases, the basic rule is that the party making allegations has the burden of proving them by a preponderance of evidence. In this regard, case law defines preponderance of evidence as the weight, cre