Case Digest (G.R. No. 180512) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jardine Davies, Inc. v. Court of Appeals and Pure Foods Corporation v. Court of Appeals, decided on June 19, 2000 under G.R. Nos. 128066 and 128069, the dispute arose when Pure Foods Corporation (“PureFoods”) held a public bidding in November 1992 for the supply and installation of two 1,500 KW generators at its Marikina plant. Out of eight pre-qualified bidders, Far East Mills Supply Corporation (“FEMSCO”) submitted the winning proposal and, on December 12, 1992, received a letter from PureFoods confirming award of the P6,137,293 contract subject to specified terms and conditions. FEMSCO furnished the required performance bond and all-risk insurance, while PureFoods returned FEMSCO’s bid bond. On December 22, 1992, PureFoods unilaterally canceled the award and, by March 1993, contracted with Jardine Davies, Inc. (“Jardine”), a non-bidder. FEMSCO sued PureFoods for breach of contract and Jardine for tortious interference. The Regional Trial Court granted Jardine’s Demurrer to Case Digest (G.R. No. 180512) Expanded Legal Reasoning Model
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)