Case Digest (G.R. No. 118438)
Facts:
The case involves Allied Agri-Business Development Co., Inc. (hereinafter referred to as "ALLIED") as the petitioner and Cherry Valley Farms Limited (hereinafter referred to as "CHERRY VALLEY") as the respondent. The events leading to the case began on October 14, 1986, when CHERRY VALLEY, a foreign corporation based in England, filed a complaint against ALLIED in the Regional Trial Court of Makati City. The complaint sought the collection of a sum of money amounting to £51,245.12, which represented the value of duck hatching eggs and ducklings purchased by ALLIED from CHERRY VALLEY between September 1, 1982, and February 16, 1983. Despite repeated demands for payment, including a letter from CHERRY VALLEY's solicitor, ALLIED failed to settle the amount owed. Instead, ALLIED's president, Ricardo Quintos, sent a letter on July 17, 1985, inviting CHERRY VALLEY to become a stockholder in a new corporation, which was rejected by CHERRY VALLEY on Septem...
Case Digest (G.R. No. 118438)
Facts:
Parties Involved:
- Petitioner: Allied Agri-Business Development Co., Inc. (ALLIED).
- Respondents: Cherry Valley Farms Limited (CHERRY VALLEY), a foreign company based in England, and the Court of Appeals.
Transaction Details:
- From 1 September 1982 to 16 February 1983, ALLIED purchased duck hatching eggs and ducklings from CHERRY VALLEY in ten (10) separate orders, totaling £51,245.12.
- ALLIED failed to pay the total purchase price despite repeated demands, including a letter from CHERRY VALLEY’s solicitor, Mr. Braithwaite, dated 22 March 1985.
- On 17 July 1985, ALLIED’s president, Ricardo Quintos, proposed forming a new corporation with CHERRY VALLEY as a stockholder, but this was rejected by CHERRY VALLEY on 26 September 1985.
- Quintos acknowledged ALLIED’s debt to CHERRY VALLEY in a letter dated 8 October 1985.
Legal Proceedings:
- On 14 October 1986, CHERRY VALLEY filed a complaint for collection of sum of money against ALLIED in the Regional Trial Court of Makati City, seeking payment of £51,245.12, legal interest, attorney’s fees, and costs of suit.
- ALLIED, in its answer, denied the material allegations, contested CHERRY VALLEY’s legal capacity to sue, and claimed that Quintos’ letter was unauthorized.
- On 19 July 1988, CHERRY VALLEY served a Request for Admission on ALLIED, seeking admissions on key facts, including the order, receipt, and acknowledgment of the debt.
- ALLIED filed Comments/Objections, arguing that the admissions were improper and immaterial.
- The trial court, on 11 August 1988, ordered ALLIED to answer the request within ten (10) days, or the matters would be deemed admitted. ALLIED failed to comply, leading to an implied admission of the facts.
- On 23 October 1990, the trial court granted CHERRY VALLEY’s motion for summary judgment, ordering ALLIED to pay £51,245.12, legal interest, attorney’s fees, and costs of suit.
- ALLIED appealed, but the Court of Appeals affirmed the trial court’s decision on 6 September 1994, modifying the judgment to delete the award of attorney’s fees and costs of suit.
- ALLIED filed the instant petition, raising issues of CHERRY VALLEY’s legal capacity to sue, due process, and the validity of the summary judgment.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Capacity to Sue of Foreign Corporations: A foreign corporation without a local license can still sue in the Philippines if the transaction is solitary and does not constitute doing business in the country. The doctrine of lack of capacity to sue is not intended to favor domestic corporations that repudiate their obligations to foreign firms.
- Request for Admission: A party’s failure to answer a request for admission within the prescribed period results in an implied admission of the facts stated in the request. The burden of affirmative action lies on the party served with the request, and silence is deemed an admission.
- Summary Judgment: Summary judgment is appropriate when there are no genuine issues of material fact, and the case can be decided based on the admitted facts.
- Due Process: Due process is satisfied when a party is given the opportunity to be heard. ALLIED had the chance to respond to the request for admission but failed to do so, and thus cannot claim denial of due process.