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Case Digest on Obligations and Contracts: Reformation of Document - First Fil-Sin Lending Corp. v. Gloria Padillo G.R. No. 160533

First Fil-Sin Lending Corp. v. Gloria Padillo
G.R. No. 160533, January 12, 2005
Facts:
On July 22, 1997, respondent Padillo obtained a P500,000.00 loan from petitioner First Fil-Sin Lending Corp. On September 7, 1997, respondent obtained another P500,000.00 loan from petitioner. In sum, she has paid a total of P792,500.00 for the first loan and P775,000.00 for the second loan.
On January 27, 2000, respondent filed an action for sum of money against petitioner , alleging that she only agreed to pay interest at the rates of 4.5% and 5% per annum  respectively, for the two loans, and not 4.5% and 5% per month. Respondent sought to recover the amounts she allegedly paid in excess of actual obligations.
Ruling:
The petition is impressed with merit. The loan obligations provide for per annum interest rates.
Reformation cannot be resorted to as the documents have not been assailed on the ground of mutual mistake.
When a party sues on a written contract and no attempt is made to show any vice therein, he cannot be allowed to lay claim for more than what its clear stipulations accord. His omission cannot be arbitrarily supplied by the courts by what their own notions of justice or equity may dictate.

Notably, petitioner even admitted that it was solely responsible for the preparation of the loan documents, and that it failed to correct the pro forma note "p.a." to "per month". Since the mistake is exclusively attributed to petitioner, the same should be charged against it. This unilateral mistake cannot be taken against respondent who merely affixed her signature on the pro forma loan agreements. As between two parties to a written agreement, the party who gave rise to the mistake or error in the provisions of the same is estopped from asserting a contrary intention to that contained therein. The checks issued by respondent do not clearly and convincingly prove that the real intent of the parties is to apply the interest rates on a monthly basis. Absent any proof of vice of consent, the promissory notes and disclosure statements remain the best evidence to ascertain the real intent of the parties.
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