Case Digest (G.R. No. 167812) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jesus M. Gozun v. Jose Teofilo T. Mercado, petitioner Gozun, owner of JMG Publishing House in San Fernando, Pampanga, agreed in early 1995 to print campaign materials for respondent Mercado’s gubernatorial bid. Upon a verbal assurance from respondent’s wife that the price quotation was approved, Gozun procured services from Metro Angeles Printing and St. Joseph Printing Press to meet urgent deadlines, producing posters, leaflets, sample ballots, poll-watcher IDs, and stickers. On March 31, 1995, respondent’s sister-in-law Lilian Soriano obtained a “cash advance” of ₱253,000 from Gozun, who recorded the amount in his diary and issued Lilian an acknowledgment receipt bearing only her name. Gozun subsequently presented Mercado a Statement of Account totaling ₱2,177,906 (₱640,310 for JMG, ₱837,696 for Metro Angeles, ₱446,900 for St. Joseph, and the ₱253,000 advance). Respondent’s wife paid ₱1,000,000 on August 11, 1995, but the balance remained unpaid despite demands. On November... Case Digest (G.R. No. 167812) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- In the 1995 Pampanga gubernatorial race, petitioner Jesus M. Gozun, owner of JMG Publishing House, submitted draft samples and price quotations for campaign materials to respondent Jose Teofilo T. Mercado.
- Respondent’s wife allegedly approved the quotation, prompting petitioner to print posters, leaflets, sample ballots, poll-watcher IDs, and stickers.
- Production and Delivery
- Due to urgency, petitioner subcontracted portions of the work to Metro Angeles Printing and St. Joseph Printing Press.
- Petitioner delivered all materials to respondent’s campaign headquarters in San Fernando, Pampanga.
- Cash Advance and Account
- On March 31, 1995, respondent’s sister-in-law Lilian Soriano obtained P253,000 “cash advance” from petitioner for poll-watcher allowances, acknowledged in petitioner’s diary.
- Petitioner later issued a Statement of Account totaling P2,177,906 (JMG Publishing House: P640,310; Metro Angeles: P837,696; St. Joseph: P446,900; cash advance: P253,000).
- Respondent’s wife paid P1,000,000; the remaining P1,177,906 remained unpaid despite demands.
- Proceedings Below
- Petitioner filed suit on November 25, 1998 for P1,177,906 plus interest and attorneys’ fees.
- Respondent denied contracting with petitioner, asserting materials were donations and Lilian lacked authority for the cash advance.
- The Regional Trial Court rendered judgment for petitioner (P1,177,906 + 12% interest + P50,000 attorneys’ fees).
- The Court of Appeals reversed, dismissing the complaint for lack of cause of action:
- No proof Lilian was authorized by respondent (Art. 1317, Civil Code).
- Metro Angeles and St. Joseph presses not impleaded as real parties in interest.
- Net claim of JMG Publishing House was already satisfied by the P1,000,000 payment.
Issues:
- Whether Lilian Soriano had actual or apparent authority to obtain a P253,000 cash advance on behalf of respondent.
- Whether petitioner, without impleading Metro Angeles Printing and St. Joseph Printing Press, could recover the amounts due those subcontractors.
- Whether petitioner is the real party in interest entitled to recover the total cost of campaign materials.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)