- Petitioner
- Danilo A. David
- Respondent
- Bank of the Philippine Islands
- Citation
- G.R. No. 251157
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Lazaro-Javier, J.
- Decided
- September 29, 2021
Summary
This Supreme Court case resolved a credit card debt dispute between Bank of the Philippine Islands and cardholder Danilo David, focusing on proper debt computation and evidence admissibility. The main controversy centered on which reference amount should be used: P278,649.87 from the formal Statement of Account or P223,749.48 from the bank's internal record. Different court levels adopted different approaches - trial courts used the internal record amount, while the Court of Appeals relied on the formal statement. The Supreme Court ultimately held that the bank's internal record was the correct reference point, constituting a declaration against interest, and applied proper payment allocation under Civil Code Article 1253 requiring interest payment before principal reduction. The Court computed David's obligation as P98,527.40 with continuing interest, demonstrating the importance of proper debt computation methodology and evidence evaluation in commercial credit disputes.