G.R. No. 133803 - Casino Jr. vs. Court of Appeals

On December 22, 1989, Octagon Realty Development Corporation (“respondent”) and Bienvenido M. Casiao, Jr. (“petitioner”) executed a contract for the supply and installation of 60,973 sq. ft. of kiln-dried narra wood parquet at the Manila Luxury Condominium Project for ₱1,158,487.00, with May 1990 as the completion date and a 40% downpayment (₱463,394.50).
Petitioner delivered only 26,727.02 sq. ft. of parquet and allegedly misrepresented his qualifications and financial capacity, prompting respondent to engage another contractor at a cost of ₱1,198,609.30.

Petitioner admitted the contract but alleged respondent’s failure to prepare the site and to pay his second and third billings (₱105,425.68) caused delays; he claimed to have delivered 29,209.82 sq. ft.
He raised affirmative defenses—prematurity, waiver, respondent’s breach—and counterclaimed for rescission, payment of ₱597,392.90 (or ₱105,425.68), damages (actual ₱600,000.00; compensatory ₱30,000.00; moral ₱100,000.00), attorney’s fees and costs.

RTC, Pasig (June 2, 1994): Found petitioner in breach; upheld respondent’s rescission under Art. 1191, awarded respondent ₱2,111,061.69 (actual and compensatory damages) and ₱50,000 attorney’s fees.
CA Decision (Jan. 21, 1997): Affirmed RTC but reduced damages to ₱1,662,003.80 plus legal interest.
CA Resolution (May 20, 1998): Denied petitioner’s motion for reconsideration; granted respondent’s motion and affirmed the RTC decision in toto.

Whether respondent validly rescinded the contract extrajudicially under Article 1191 of the Civil Code.
Whether the award of actual and compensatory damages (₱1,662,003.80) with legal interest was legally justified and sufficiently proven.
Whether the CA committed grave abuse of discretion or contravened law or fact in affirming the lower courts.