Title
Dino vs. Court of Appeals
Case
G.R. No. 113564
Decision Date
Jun 20, 2001
Petitioners sued respondent for defective goods; Court dismissed case due to prescription, ruling action filed beyond six-month warranty period.

Case Digest (G.R. No. 203984)
Expanded Legal Reasoning Model

Facts:

  • Parties
    • Petitioners Inocencia Yu Dino and her husband, doing business as Candy Claire Fashion Garments, manufacturers and sellers of shirts.
    • Respondent Roman Sio, part owner and general manager of Universal Toy Master Manufacturing, a manufacturing corporation.
  • Contractual Agreement
    • Petitioners and Sio entered into a contract for the manufacture of 20,000 vinyl frogs and 20,000 vinyl mooseheads at ₱7.00 per piece, according to approved samples.
    • The manufactured items were to be attached to the shirts sold by petitioners.
  • Delivery, Payment, and Return of Defective Goods
    • Sio delivered the 40,000 pieces in several installments, the last on September 28, 1988.
    • Petitioners paid the full purchase price but later returned 29,772 pieces for hidden defects.
      • First return: December 12, 1988 (1,720 pieces)
      • Second return: January 11, 1989
      • Third return: January 17, 1989
    • Petitioners demanded a refund of ₱208,404.00, which Sio refused.
  • Procedural History
    • Petitioners filed a complaint for collection of sum of money on July 24, 1989, in RTC Manila, Branch 38.
    • RTC rendered judgment on June 5, 1990, awarding ₱208,404.00 with interest from July 5, 1989, plus ₱20,000.00 attorney’s fees.
    • Respondent appealed to the Court of Appeals (CA), which on April 30, 1993, affirmed the RTC decision.
    • Sio filed a Motion for Reconsideration in the CA, raising prescription. On January 24, 1994, the CA reversed and dismissed the complaint as time-barred.
    • Petitioners elevated the case to the Supreme Court via petition for review on certiorari.

Issues:

  • Nature of the action: collection of sum of money or action for breach of warranty?
  • Whether the defense of prescription, not raised in the answer, may be considered when the complaint on its face shows the action is time-barred.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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