Title
Bean vs. B.W. Cadwallader Co.
Case
G.R. No. L-4175
Decision Date
Mar 26, 1908
Plaintiff fulfilled timber delivery obligations; defendant breached by failing to provide adequate transport. Court awarded unpaid balances, damages, and interest.
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Case Digest (G.R. No. L-4175)

Facts:

  1. Contractual Agreements: On September 6, 1905, the plaintiff, George Case, and the defendant, The B. W. Cadwallader Company, entered into a written contract (Exhibit A) where Case agreed to furnish and sell a cargo of ipil and molave timber to the defendant for 60 cents per cubic foot, delivered alongside the defendant's vessel at Basilan within three months. On January 3, 1906, a second contract (Exhibit B) was made, where Case agreed to deliver another cargo of native timber (calantas, ipil, and mangachupay) under specified conditions.
  2. Plaintiff's Performance: Case fulfilled his obligations by cutting and transporting the timber to the beach at Basilan, measuring it, and placing it on rafts for delivery. He notified the defendant via telegram that the timber was ready for shipment within the agreed time frame.
  3. Defendant's Default: Despite Case's readiness, the defendant failed to provide adequate transportation to load the timber. Attempts to load the timber using the defendant's vessel, the Juanita, were unsuccessful due to the vessel's inadequate equipment.
  4. Payments and Balances: The defendant made partial payments of P2,500 on December 29, 1905, and P1,000 on February 6, 1906. However, a balance of P7,356.80 under Exhibit A and P2,782.75 under Exhibit B remained unpaid. Case also claimed P810 in damages due to the defendant's breach of contract.
  5. Defendant's Defense: The defendant claimed that the plaintiff misrepresented the conditions at Basilan, making it impossible to load the timber, and argued that it had not received or accepted the timber. The defendant also contended that the plaintiff had not fulfilled his obligations under the contracts.

Issue:

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Ruling:

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Ratio:

  1. Fulfillment of Contractual Obligations: The plaintiff had done everything required under the contracts, including cutting, measuring, and placing the timber on rafts for delivery alongside the defendant's vessel. The defendant's inability to load the timber due to inadequate equipment did not relieve it of its contractual obligations.
  2. Title and Delivery: Under the Civil Code, manual delivery is not necessary for the transfer of title unless explicitly required by the contract. The parties agreed that delivery would be made alongside the defendant's vessel, and the plaintiff complied with this condition.
  3. Defendant's Default: The defendant's failure to provide adequate transportation and equipment constituted a breach of contract. The plaintiff incurred damages as a result, including expenses for borrowing money and travel.
  4. Preponderance of Evidence: The court found that, based on the evidence, it was feasible to load the timber at Basilan with proper equipment. The defendant's claim of impossibility was not supported by the preponderance of evidence.


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