Title
Jardine Davies Inc. vs. Court of Appeals
Case
G.R. No. 128066
Decision Date
Jun 19, 2000
PUREFOODS awarded FEMSCO a generator contract, then canceled it and awarded JARDINE. Court ruled PUREFOODS breached contract, liable for damages; JARDINE not liable for inducement.

Case Digest (G.R. No. 180512)
Expanded Legal Reasoning Model

Facts:

  • Pre-contractual negotiations and bidding
    • In 1992, amid a national power crisis, Pure Foods Corporation (Pure Foods) invited suppliers to bid for the supply and installation of two 1,500 KW generators at its Marikina plant.
    • Far East Mills Supply Corporation (FEMSCO), Monark, and Advance Power submitted bids with the required 5% bid bonds.
  • Contract award and initial compliance
    • On December 12, 1992, Pure Foods wrote FEMSCO that “Pure Foods Corporation has awarded to your firm the project…,” specifying lump‐sum price, progress billing, retention, bonds, insurance, warranty, and completion deadline.
    • FEMSCO posted the 30% performance bond and all‐risk insurance; Pure Foods acknowledged receipt and returned FEMSCO’s bid bond; FEMSCO ordered materials.
  • Cancellation and parallel proceedings
    • On December 22, 1992, Pure Foods unilaterally canceled the award citing “significant factors” and later (March 26, 1993) contracted with Jardine Davies, Inc. (Jardine), a non‐bidder.
    • FEMSCO demanded compliance; upon no redress, it sued Pure Foods for breach and Jardine for tortious interference.
  • Trial court and Court of Appeals decisions
    • RTC (June 27, 1994) granted Jardine’s demurrer to evidence, dismissing FEMSCO’s complaint against Jardine; on July 28, 1994, it ordered Pure Foods to pay FEMSCO P2,300,000 (engineering services), US$14,000, P900,000 (markup), 20% attorney’s fees, and costs.
    • CA (August 14, 1996) affirmed the RTC decision against Pure Foods; reversed the demurrer ruling and held Jardine liable for P2,000,000 moral damages; imposed additional P2,000,000 moral and P1,000,000 exemplary damages plus 20% attorney’s fees on Pure Foods.
    • Both Pure Foods and Jardine filed petitions for review with the Supreme Court.

Issues:

  • Whether a perfected contract existed between Pure Foods and FEMSCO.
  • Whether Jardine induced or connived with Pure Foods to violate its contract with FEMSCO.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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