Title
Bernardo vs. Caltex , Incorporated
Case
G.R. No. 101345
Decision Date
Dec 1, 1992
Petitioner paid Caltex for fuel, but delivery was withheld due to a price hike. SC ruled RTC has jurisdiction; Caltex must deliver at pre-paid prices.
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Case Digest (G.R. No. 101345)

Facts:

  1. Parties Involved:

    • Petitioner: Nonito J. Bernardo, an operator/dealer of two Caltex gasoline stations.
    • Respondent: Caltex (Philippines), Inc., an oil company.
  2. Transactions:

    • On December 3, 1990, Bernardo placed an order for 10,000 liters of diesel fuel with Caltex's Pandacan Terminal and made full payment of P57,937.50, evidenced by an official receipt.
    • On December 4, 1990, Bernardo placed another order for 10,000 liters of premium gasoline and made full payment of P84,193.50 on December 5, 1990, evidenced by an official receipt.
  3. Delivery Issues:

    • Bernardo sent his tanker to the Pandacan Terminal on December 5, 1990, to take delivery of the petroleum products. However, delivery was not made due to a computer system malfunction at Caltex from 3:45 A.M. to 12:10 P.M. on the same day.
    • At 6:00 P.M. on December 5, 1990, the Energy Regulatory Board (ERB) announced a price increase for petroleum products. Caltex cut off deliveries to adjust its systems and invoiced all orders at the new rates, including Bernardo's pre-paid orders.
  4. Demands and Refusal:

    • Bernardo demanded delivery of the petroleum products, but Caltex refused unless Bernardo paid the price difference due to the ERB's price increase.
    • Caltex cited Section 3 of the Purchase and Sale Agreement, which stated that prices would be based on the official wholesale selling price on the date of delivery.
  5. Legal Proceedings:

    • On January 8, 1991, Bernardo filed a complaint in the Regional Trial Court (RTC) of Quezon City, seeking delivery of the petroleum products and damages.
    • Caltex moved to dismiss the case, arguing improper venue and lack of cause of action. The RTC denied the motion and issued a preliminary mandatory injunction for delivery.
    • Caltex filed a special civil action of certiorari, which was referred to the Court of Appeals (CA). The CA upheld the denial of the motion to dismiss but set aside the preliminary injunction.
    • The RTC later dismissed Bernardo's suit for lack of jurisdiction, citing the CA's ruling and the Energy Regulatory Board's jurisdiction over disputes between oil companies and dealers.

Issue:

  1. Jurisdictional Issue:

    • Whether the Regional Trial Court or the Energy Regulatory Board (ERB) has jurisdiction over the dispute between Bernardo and Caltex regarding the delivery of petroleum products and the applicable prices.
  2. Contractual Issue:

    • Whether Caltex was obligated to deliver the petroleum products at the pre-paid prices or at the new prices set by the ERB on December 5, 1990.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court granted Bernardo's petition, annulled the RTC's dismissal order, and directed the RTC to proceed with the case. The dispute is a civil law matter within the jurisdiction of the RTC, and Caltex is obligated to deliver the petroleum products at the prices prevailing at the time of Bernardo's payment.


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