Title
Aguado vs. City of Manila
Case
G.R. No. L-3282
Decision Date
Jan 9, 1908
Ricardo Aguado sought payment from the City of Manila for unpaid coal deliveries and a deposit under a contract with the defunct Ayuntamiento de Manila. The Supreme Court ruled the City of Manila is not liable as it is not the Ayuntamiento's successor and holds no trust over Carriedo funds.
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Case Digest (G.R. No. L-3282)

Facts:

Background of the Parties

  • The plaintiff, Ricardo Aguado, is the assignor of claims held by Tomas Luna Munoz against the defendant, the City of Manila, as the administrator of the Water Supply and Carriedo Funds.
  • The defendant, the City of Manila, is a municipal corporation organized under the laws of the Philippine Islands since July 31, 1901.

Contractual Agreement

  • On June 11, 1897, Tomas Luna Munoz entered into a contract with the Ayuntamiento de Manila (the predecessor of the City of Manila) for the sale and delivery of coal.
  • Under the contract, Munoz delivered 1,340.30 tons of coal before April 1, 1898, and received payment of 16,083.60 pesos (Mexican currency).
  • Between April 1, 1898, and April 30, 1898, Munoz delivered an additional 259.70 tons of coal, valued at 3,116.40 pesos (Mexican currency), which remained unpaid.

Deposit as Guaranty

  • On June 1, 1897, Munoz deposited 1,920 pesos (Mexican currency) with the Ayuntamiento de Manila as security for the fulfillment of the contract.
  • Munoz fulfilled all contractual obligations, but the deposit was not returned despite repeated demands.

Delivery of Australian Coal

  • On June 30, 1898, Munoz delivered 39 tons of Australian coal to the Ayuntamiento de Manila for the Carriedo waterworks, valued at 585 pesos (Mexican currency). This amount also remained unpaid.

Change in Government

  • On August 13, 1898, the Ayuntamiento de Manila was suspended due to the U.S. military occupation of Manila. The Military Government of the U.S. took over the administration of the Carriedo funds and waterworks.
  • On August 6, 1901, the City of Manila became the successor to the Ayuntamiento de Manila and the Military Government in administering the Carriedo funds and waterworks.

Demands for Payment

  • Munoz and later Aguado made repeated demands for payment of the unpaid amounts (3,116.40 pesos for coal, 1,920 pesos for the deposit, and 585 pesos for Australian coal) to the Ayuntamiento de Manila, the Military Government, and the City of Manila, but no payment was made.

Stipulated Facts

  • The parties agreed on a statement of facts, including the history of the Carriedo waterworks, the transfer of funds to the U.S. Military Government, and the City of Manila's administration of the Carriedo funds and waterworks.

Lower Court Decision

  • The lower court ruled in favor of Aguado, ordering the City of Manila to pay 5,621.40 pesos plus interest, totaling 7,982.38 pesos, and allowed execution against the Carriedo funds and waterworks.

Issue:

  1. Whether the City of Manila is liable for the obligations incurred by the Ayuntamiento de Manila under the contracts with Tomas Luna Munoz.
  2. Whether the City of Manila holds the Carriedo funds and waterworks in trust, making them subject to execution for the payment of the debt.
  3. Whether the plaintiff, Ricardo Aguado, is entitled to recover from the City of Manila as the successor to the Ayuntamiento de Manila.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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