Title
D.M. Wenceslao and Associates, Inc. vs. Freyssinet Philippines, Inc.
Case
G.R. No. 166857
Decision Date
Sep 11, 2009
A construction company is liable for unpaid pre-stressed piles with reduced interest, affirming the trial court's jurisdiction and ruling out joint liability for the company's president.
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Case Digest (G.R. No. 166857)

Facts:

  • D.M. Wenceslao & Associates, Inc. (DMWAI) is the petitioner; Freyssinet Philippines, Inc. (FPI) is the respondent.
  • In January 1989, DMWAI was contracted to construct the National Historical Institute Building (NHI project).
  • On January 6, 1989, Delfin J. Wenceslao, Jr. accepted a contract from FPI for pre-stressed piles worth P2,600,000.
  • The contract required a 30% down payment and 70% through progress payments, with an 18% per annum interest on delinquent accounts.
  • FPI claimed the NHI project was completed in November 1989, but full payment for the piles was unpaid.
  • On August 5, 1993, FPI filed a complaint for P322,413.15, plus interest and attorney's fees.
  • FPI amended the complaint to include DMWAI as a defendant, which Wenceslao, Jr. opposed.
  • The trial court admitted the amended complaint on July 12, 1994.
  • On April 17, 1997, the Regional Trial Court ruled in favor of FPI, ordering payment from both defendants.
  • DMWAI appealed, contesting the trial court's decisions.
  • The Court of Appeals modified the ruling on August 10, 2004, holding DMWAI solely liable for P322,413.15 with a 6% interest rate.
  • DMWAI's motion for reconsideration was denied on January 21, 2005.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied DMWAI's petition.
  • The Court affirmed the Court of Appeals' decisions regarding DMWAI's liab...(Unlock)

Ratio:

  • The Supreme Court held that the trial court had jurisdiction over the IBRD account due to DMWAI's implied consent, as it did not object to the evidence presented during the trial.
  • The Court emphasized that issues can be judged if evidence is presented with the other party's consent.
  • DMWAI's claim that the IBRD account was not part of the original...continue reading

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