Case Digest (G.R. No. 200602) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In ACE Foods, Inc. v. Micro Pacific Technologies Co., Ltd., ACE Foods, a domestic corporation dealing in wholesale and retail distribution of consumer goods, received on September 26, 2001 a letter-proposal from MTCL, a supplier of computer hardware, offering Cisco routers and Frame Relay products. The proposal specified payment “Thirty (30) days upon delivery,” delivery terms, price validity, and a one-year warranty. On October 29, 2001, ACE Foods accepted the offer by issuing Purchase Order No. 100023 for ₱646,464.00. MTCL delivered, installed, and configured the equipment on March 4, 2002, issuing Invoice No. 7733 which contained a title reservation clause reserving ownership until full payment. ACE Foods used the products but refused to pay the price. Instead, on September 19, 2002 ACE Foods notified MTCL of its intention to return the equipment for alleged defects and failure to perform “after delivery services” (installation, cost benefit study, and training). On October 1... Case Digest (G.R. No. 200602) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Parties
- ACE Foods, Inc. – Domestic corporation engaged in wholesale and retail trading and distribution of consumer goods.
- Micro Pacific Technologies Co., Ltd. (MTCL) – Supplier of computer hardware and equipment.
- Formation of the Contract
- September 26, 2001 – MTCL sent ACE Foods a letter-proposal offering Cisco routers and frame-relay products, with terms: payment in 30 days upon delivery; prices based on current dollar rate subject to change; immediate delivery if in stock or 30–45 days upon PO receipt; one-year parts/service warranty (accessories excluded).
- October 29, 2001 – ACE Foods accepted and issued Purchase Order No. 100023 for P646,464.00.
- Delivery, Invoice, and Subsequent Refusal to Pay
- March 4, 2002 – MTCL delivered the products, issued Invoice No. 7733 containing a “title reserved” stipulation until full payment, and installed/configured the equipment at ACE Foods’s premises.
- September 3, 2002 – MTCL demanded payment; ACE Foods refused and, by letter dated September 19, 2002, claimed to return the products for alleged defects and unperformed “after-delivery services.”
- October 16, 2002 – ACE Foods filed a complaint in RTC Makati for MTCL to withdraw the products, alleging breach of installation, cost-benefit study, and training obligations, and asserting defects.
- Judicial Proceedings
- RTC Decision (February 28, 2007) – Held the transaction to be a contract to sell due to the invoice’s title reservation clause; ordered MTCL to remove the products and awarded ACE Foods actual damages (P200,000) and attorney’s fees (P100,000).
- CA Decision (October 21, 2011) – Reversed RTC, ruled it was a perfected contract of sale; ordered ACE Foods to pay P646,464.00 plus 6% interest from April 4, 2002, and attorney’s fees of P50,000.00.
- CA Resolution (February 8, 2012) – Denied ACE Foods’s motion for reconsideration.
- Supreme Court Petition – ACE Foods sought certiorari review of the CA decisions.
Issues:
- Whether ACE Foods is obligated to pay MTCL the purchase price for the subject products.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)