De Guzman vs. Court of Appeals

Factual findings of the trial court that are affirmed in toto by the Court of Appeals are conclusive and binding upon the Supreme Court; furthermore, a photocopy of a document is admissible as secondary evidence when the due execution of the original is proven and its loss or destruction is adequately explained, and mere denial unsubstantiated by clear and convincing evidence is a self-serving defense that cannot prevail over affirmative testimony.

The dispute arose from a familial conflict between sisters-in-law concerning the management of a riceland owned in common by the petitioner's deceased husband and private respondent Lucila De Guzman. The conflict escalated when private respondents claimed that petitioner, who allegedly managed the property, failed to deliver their share in the harvest, leading to a demand for 1,500 cavans of palay and subsequently a claim for P92,000.00 based on an alleged written acknowledgment of debt.

• Petitioner Celestina De Guzman and private respondent Lucila De Guzman-Sioson were sisters-in-law, petitioner being the widow of Lucila's elder brother, Andres De Guzman.
• Private respondents claimed that petitioner managed a riceland owned in common by Lucila and petitioner's deceased husband, Andres, but failed to deliver Lucila's share in the harvest.
• In May 1987, private respondent Cresenciano Sioson wrote petitioner demanding delivery of 1,500 cavans of palay.
• In July 1987, Cresenciano received by mail a letter (Exhibit C) from petitioner acknowledging a debt of P92,000.00 and offering to pay it at any time the respondents would claim it.
• Cresenciano initially refused the P92,000.00 offer but later agreed to accept it after negotiations because he was in dire need of money; however, petitioner failed to pay despite the agreement.
• Private respondents sent a demand letter through counsel, which petitioner ignored, prompting them to file the collection suit.
• Petitioner denied all allegations, claiming she was not the farm manager, never sent the letter, and that the letter was a forgery.
• During cross-examination, petitioner denied that signatures on several documents shown to her were hers, but on redirect examination, she made a complete turnabout and acknowledged that the signatures were actually hers.
• The original of Exhibit C was allegedly lost after Cresenciano brought it to a photocopying service at the Cabanatuan City Hall on May 31, 1989, during a hearing at the Office of the City Fiscal; he forgot to retrieve the original from the photocopying machine operator and could not locate it despite diligent search.

• The lower court erred in giving credence to the plaintiff's testimony that the defendant acknowledged the payment of P92,000.00 as shown in Exhibit "C".
• The lower court erred in believing the loss of the original of Exhibit "C".
• The lower court erred in not dismissing the case and in not granting damages to the defendant in view of the filing of a malicious and vindictive case, instead granting damages to the plaintiffs.
• Petitioner denied being indebted and claimed the letter was a forgery, denied being the farm manager, and denied being confronted by Cresenciano about the letter.

• Procedural:
  • Whether the Supreme Court should review and disturb the factual findings of the trial court as affirmed in toto by the Court of Appeals.
  • Whether the photocopy of the acknowledgment letter (Exhibit C) was properly admitted as secondary evidence despite the loss of the original.
• Substantive Issues:
  • Whether petitioner is liable to pay private respondents P92,000.00 based on the acknowledgment letter.
  • Whether the two-year delay in filing the suit affects the validity of the claim.
  • Whether petitioner's defense of denial constitutes sufficient evidence to overcome the affirmative evidence presented by private respondents.

• Procedural:
  • The Supreme Court held that it is not its function to analyze and weigh evidence anew where the factual findings of the trial court are affirmed in toto by the Court of Appeals, as its jurisdiction is limited to reviewing errors of law.
  • The Court ruled that the photocopy was properly admitted as secondary evidence under Rule 130, Section 4 of the Rules of Court because the due execution of the original was proven through handwriting comparison with petitioner's acknowledged signatures, and the loss of the original was adequately explained by private respondent Cresenciano through testimony regarding the circumstances of the loss at the photocopying center.
• Substantive:
  • The Court held that petitioner is liable for the P92,000.00 debt, finding that her defense of mere denial was unsubstantiated and self-serving, particularly in light of her contradictory testimony regarding her signatures on other documents which rendered her testimony unworthy of credence.
  • The Court ruled that the delay in filing the suit was justified by the parties' attempts to reach an amicable settlement, which the law encourages, and therefore should not prejudice the respondents' claim.

• Conclusiveness of Factual Findings — Factual findings of the trial court that are affirmed in toto by the Court of Appeals are conclusive and binding upon the Supreme Court, which will not disturb such findings as they are not reviewable by certiorari.
• Secondary Evidence — When the original writing has been lost or destroyed, its contents may be proved by a copy or by recollection of witness, provided the execution and loss or destruction of the original are proven.
• Handwriting Comparison — Evidence respecting handwriting may be given by a comparison made by the court with writings admitted or treated as genuine by the party against whom the evidence is offered.
• Weight of Denial — Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence which has no weight in law and cannot be given greater evidentiary value over the testimony of credible witnesses who testified on affirmative matters.

• "It is not the function of this Court to analyze and weigh evidence by the parties all over again. Our jurisdiction is in principle limited to reviewing errors of law that might have been committed by the Court of Appeals."
• "A fortiori, where the factual findings of the trial court are affirmed in toto by the Court of Appeals, there is greater reason for not disturbing such findings and for regarding them as not reviewable by this Court."
• "Denial, if unsubstantiated by clear and convincing evidence, is a negative and self-serving evidence which has no weight in law and cannot be given greater evidentiary value over the testimony of credible witnesses who testified on affirmative matters."
• "The law encourages the amicable settlement not only of pending cases but also of disputes which might otherwise be filed in court."

• Gobonseng, Jr. v. Court of Appeals — Cited for the principle that the Supreme Court's jurisdiction is limited to reviewing errors of law committed by the Court of Appeals.
• Pantranco North Express, Inc. v. Court of Appeals — Cited for the same principle regarding the limited jurisdiction of the Supreme Court to errors of law.
• Meneses v. Court of Appeals — Cited for the principle that factual findings of the trial court affirmed by the Court of Appeals should not be disturbed.
• Abadilla v. Tabiliran, Jr. — Cited for the rule that unsubstantiated denial is negative and self-serving evidence with no weight in law.
• First Intramuros BF Condominium v. NLRC — Cited for the principle that the law encourages amicable settlement of disputes.
• Court Administrator v. Villanueva — Cited for the rule that evidence respecting handwriting may be given by comparison with writings admitted or treated as genuine.
• People v. Goce — Cited for the rule regarding the admissibility of secondary evidence when the original writing has been lost or destroyed.
• De Vera v. Aguilar — Cited for the same rule regarding secondary evidence under Rule 130.

• Rule 130, Section 4 of the Revised Rules of Court — Provides for the admissibility of secondary evidence when the original writing has been lost or destroyed, upon proof of its execution and loss or destruction.