Case Digest (G.R. No. 158086) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In ASJ Corporation and Antonio San Juan v. Sps. Efren & Maura Evangelista (G.R. No. 158086, February 14, 2008), respondents Efren and Maura Evangelista operated a large‐scale hatchery business under the trade name R.M. Sy Chicks in Bulacan and Nueva Ecija. In 1991 they entered into a contract with ASJ Corporation, a family‐owned company controlled by petitioner Antonio San Juan, whereby ASJ Corp. would incubate and hatch broiler eggs delivered by respondents for a service fee of ₱0.80 per egg. Each batch was documented by a “Setting Report” specifying delivery, candling, and hatch dates, and respondents initially paid upon collection of chicks and egg by‐products. Beginning January 13 to February 3 1993, respondents delivered 101,350 eggs under Setting Reports 108 to 113 but failed to fully pay their accumulated fees from prior batches (Setting Report No. 90 onward). On February 3 and 10, 1993, San Juan refused to release the chicks and by‐products under Reports 108 and 109 unti Case Digest (G.R. No. 158086) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Contractual Arrangement
- Petitioners ASJ Corporation (ASJ Corp.) and Antonio San Juan operated a hatchery; respondents Efren and Maura Evangelista, doing business as R.M. Sy Chicks, supplied broiler eggs for incubation at a service fee of ₱0.80 per egg.
- Deliveries were documented by Setting Reports, showing number of eggs set, dates of setting, candling, hatching, and pick-up.
- Deliveries, Non-payment and Withholding
- From January 13 to February 3, 1993, respondents delivered 101,350 eggs under Setting Reports Nos. 108–113, with pick-up dates ranging from February 3 to 24, 1993.
- Petitioners refused to release chicks and by-products under SR 108 and 109 for accumulated unpaid fees from SR 90 onward, accepted partial cash payments (₱15,000 twice) but insisted on full settlement; threatened to impound respondents’ vehicle and detain them if they returned without full payment.
- Respondents, fearing threats, did not retrieve chicks under SR 110–113 and filed suit for damages for unjustified retention with threats and intimidation.
- Trial and Appellate Proceedings
- RTC of Malolos, Bulacan (July 8, 1996) found respondents owed ₱102,336.80 as of SR 107; petitioners unjustifiably retained chicks under SR 108–113; pierced veil of corporate fiction; held ASJ Corp. and San Juan solidarily liable for ₱529,644.80 actual damages, ₱100,000 moral, ₱50,000 attorney’s fees, plus interest and costs.
- Court of Appeals (April 30, 2003) affirmed RTC, added exemplary damages of ₱10,000; denied respondents’ claim for unrealized profits and additional by-products; denied petitioners’ appeal.
- Petitioners elevated the case to the Supreme Court via Rule 45 petition, assigning errors on withholding, hearsay, non-pickup, piercing veil, awards of damages, and denial of counterclaim.
Issues:
- Factual and Evidentiary Questions
- Whether petitioners legitimately withheld chicks and by-products under SR 108–109 and whether hearsay testimony was improperly admitted.
- Whether respondents failed to return for SR 110–113, absolving petitioners of liability.
- Legal Questions
- Whether piercing the corporate veil of ASJ Corp. was justified, making San Juan personally liable.
- Whether petitioners’ retention and threats constituted an abuse of rights, justifying awards of actual, temperate, moral, exemplary damages, and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)