Title
Chevron Philippines, Inc. vs. Looyuko
Case
G.R. No. 236525
Decision Date
Mar 29, 2023
Chevron sued Noah’s Ark Sugar Refinery and Alberto Looyuko for unpaid petroleum invoices. SC reversed CA, upheld RTC with modified interest rates, and awarded attorney’s fees.

Case Digest (G.R. No. 236525)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioner Chevron Philippines, Inc. (formerly Caltex Philippines, Inc.) filed a complaint for collection of sum of money against respondents Alberto T. Looyuko (doing business as "Noah's Ark Group of Companies"), his heirs, Noah's Ark Sugar Refinery, Inc., Achilles "Kelly" L. Pacquing, Julieta "Juliet" T. Go, and the heirs of Teresita C. Looyuko.
    • The complaint alleged respondents’ failure to pay for petroleum products and related services purchased from petitioner from April to November 1997, amounting to PHP 7,381,510.70 as of September 30, 1998, plus interest and attorney's fees.
  • Transactions and Demand
    • Purchases involved petroleum products including bunker fuel oil and pumping/sealing services, delivered to Noah's Ark Sugar Refinery in Mandaluyong City.
    • Transactions were evidenced by 105 invoices issued in the name of Noah's Ark Sugar Refinery, Inc.
    • Petitioner sent demand letters dated April 3, April 20, and August 10, 1998 to respondents Julieta and Achilles, requesting payment proposals and eventual payment, but these went unanswered.
  • Respondents’ Position and Pleadings
    • Respondent Alberto filed a motion to dismiss based on lack of proper summons service; substituted service was upheld by the trial court.
    • Respondents Achilles and Julieta filed an answer denying employment as officers of Noah's Ark Sugar Refinery and participation in the transactions, stating the refinery was a sole proprietorship under Alberto Looyuko.
    • They averred they were not parties to the transactions and denied any promise to provide payment proposals.
    • Respondent Alberto denied owning or transacting on behalf of Noah's Ark Group of Companies or the refinery, denied knowledge or receipt of the demand letters, and asserted the refinery ceased operations in November 1997 without his authorization for the transactions in question.
    • Alberto counterclaimed for moral damages, exemplary damages, attorney’s fees, and requested dissolution of the preliminary attachment over his properties.
  • Trial Court Proceedings
    • The trial court denied Alberto’s motion to dismiss, and Alberto participated until his death in 2004, with his heirs substituted in the case.
    • The trial court rendered judgment in favor of petitioner, ordering respondents (Alberto and his heirs) to pay the principal amount, interest based on 24% per annum, attorney’s fees, and costs.
    • Respondents Julieta and Achilles were dismissed as defendants due to lack of evidence.
    • The trial court found Alberto personally liable despite lack of signature on invoices because deliveries were indubitably made to and accepted by the refinery; Julieta and Achilles were found employees or agents but not liable due to lack of evidence of their roles in the transactions.
    • Respondents filed an appeal.
  • Court of Appeals (CA) Ruling
    • The CA reversed and set aside the trial court’s decision and dismissed the complaint.
    • CA held that there was no perfected contract of sale as:
a) No purchase order or sales contract showed Looyuko's consent and meeting of minds with petitioner. b) Delivery was not sufficiently proven as products were delivered by a third-party hauler, and no authenticated signatures confirmed proper receipt by Noah’s Ark or Looyuko. c) Partial execution did not remove the case from the Statute of Frauds, as essential contractual elements were not proven.
  • CA also noted the unusual character of the alleged default, given Noah’s Ark’s prior good payment record.
  • Petitioner’s motion for reconsideration was denied.
  • Present Petition
    • Petitioner filed a Petition for Review on Certiorari to the Supreme Court, challenging the CA’s ruling.

Issues:

  • Whether respondents’ appeal should be dismissed outright for failure to include proper page references to the records as required under Section 1(f), Rule 50 of the Rules of Court.
  • Whether there is sufficient evidence to establish a contractual relationship and liability between petitioner and respondents in relation to the alleged sales and deliveries of petroleum products and services.
  • Whether the trial court erred in imposing and upholding a 24% interest rate on the unpaid principal as stipulated in the invoices.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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