Rosella D. Canque v. The Court of Appeals

Summary

This case involves a contractual dispute between RDC Construction (petitioner Canque) and Socor Construction Corporation over payment for construction materials. Socor sued for P299,717.75 balance after delivering materials under two subcontracts for government road projects. Petitioner refused payment claiming absence of required delivery receipts. The main legal issue was whether business account entries could constitute competent evidence of deliveries. The Supreme Court ruled that while Socor's Book of Collectible Accounts failed to meet the strict requirements for business entries exception to hearsay rule, other documentary evidence sufficiently proved the deliveries and petitioner's obligation. The Court found petitioner would be unjustly enriched since she collected full project costs from government but refused to pay her subcontractor. The decision clarifies evidentiary requirements for business records and emphasizes that contractual conditions for proof of performance don't preclude alternative evidence methods.