G.R. No. 95026 - Spouses Telan vs. Court of Appeals

Parties and Background
Petitioner Eriks Pte. Ltd. is a foreign corporation organized under Singapore law, manufacturing and selling industrial sealing‐pump elements, valves, control equipment, and PVC pipes and fittings. It is not licensed to do business in the Philippines.
Respondent Delfin F. Enriquez, Jr. is a Filipino businessman operating as Delrene EB Controls Center and/or EB Karmine Commercial.

Sales Transactions
Between January 17 and August 16, 1989, petitioner sold goods to respondent under sixteen separate invoices, delivered F.O.B. Singapore, aggregating S$41,927.43, on 90-day credit terms.
Deliveries were made via airfreight or self-collect; petitioner repeatedly demanded payment, which respondent did not make.

Judicial Proceedings
On August 28, 1991, petitioner filed Civil Case No. 91-2373 with RTC Makati, Branch 138, seeking recovery of S$41,939.63 (plus interest and damages). Respondent moved to dismiss for lack of capacity to sue (no business license).
On March 8, 1993, the RTC granted the motion and dismissed the complaint, holding petitioner was doing business without a license.
On January 25, 1995, the Court of Appeals (Seventh Division) affirmed the dismissal, ruling the sales were not isolated transactions and petitioner lacked capacity to sue.
Petitioner then filed a petition for review (G.R. No. 118843) before the Supreme Court.

Capacity to Sue
Whether a foreign corporation transacting business in the Philippines without a license is barred from maintaining an action in Philippine courts under Corporation Code Sec. 133.
Whether the sequence of sixteen transactions over five months qualifies as “isolated transactions,” thus exempting petitioner from the licensing requirement.