Title
De la Rosa vs. Bank of the Philippine Islands
Case
G.R. No. 22359
Decision Date
Nov 28, 1924
Bank contest for building designs; plaintiff sued for damages due to delayed prize awards. Court ruled no breach, as date wasn’t essential, no demand made, and prizes were eventually awarded.

Case Digest (G.R. No. 22359)
Expanded Legal Reasoning Model

Facts:

  • Contest Announcement and Participation
    • The defendant bank initiated and publicly advertised a contest inviting designs and plans for the construction of a building with an announcement that prizes would be awarded not later than November 30, 1921.
    • The advertisement constituted an offer to the general public, creating an obligation once a contestant acted upon it.
  • Plaintiff’s Involvement and Expenditures
    • The plaintiff, Ulio de la Rosa, participated in the contest by submitting his designs and plans.
    • In doing so, the plaintiff incurred considerable labor and expenses, relying on the bank’s advertised conditions and promised awards.
  • Allegation of Noncompliance by the Bank
    • The plaintiff alleged that the bank failed to name judges and delayed or refrained entirely from awarding the prizes in accordance with the stipulated conditions.
    • The plaintiff sought damages amounting to P30,000 plus legal interest and costs for the breach of the advertised promise.
  • Trial Court Decision
    • After trial, the court rendered a judgment ordering the defendant bank to pay the plaintiff an indemnity of P4,000 along with the costs incurred.
    • Both parties subsequently appealed the decision, with the plaintiff contending that the amount was insufficient and that the bank had indeed breached its obligation.

Issues:

  • Essentiality of the Designated Award Date
    • Whether the stipulated date—November 30, 1921—for awarding the prizes was an essential term of the contract.
    • Whether the failure to meet that date constituted a breach of contract by the defendant bank.
  • Determination of Default
    • Whether the defendant bank was in default merely by the lapse of the specified time frame without a judicial or extrajudicial demand for performance.
    • Whether the plaintiff had effectively established the bank’s default under the provisions of paragraph 2 of Article 1100 of the Civil Code.
  • Appropriate Remedy and Award
    • Whether the indemnity sum of P4,000 awarded by the trial court was just and reasonable.
    • Whether the plaintiff was entitled to the larger sum (P30,006) as prayed for in the complaint based on the alleged breach.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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