G.R. No. 21924 - Juco vs. Cuaycong

On June 27, 1919, the defendants Cuaycong and Tongoy executed a written document acknowledging receipt of P6,000 from the plaintiff as advance payment for the sale of 1,000 piculs of sugar.
The document stipulated the delivery of the sugar on or before March 1, 1920.
Mariano Ramos signed the contract as a guarantor, agreeing to ensure repayment of the P6,000 with interest at 8% per annum if the defendants failed to deliver the sugar.

The document contained a clause providing that if the seller failed to deliver the specified sugar, the seller would have to pay not only the P6,000 but also 8% per annum on that sum.
An additional clause bound guarantor Ramos to pay the full amount due from the seller—including the sum of P6,000, interest at 8% per annum, and all expenses and attorney’s fees—should the seller default.
The plaintiff contended that these additional clauses were inserted without his knowledge and consent, arguing that the document did not reflect the true agreement between the parties.

The defendants explained that due to fierce competition among sugar buyers in Iloilo, they doubted their ability to deliver the sugar because they had already sold their expected harvest production.
They informed the plaintiff of these doubts, but he insisted on executing the contract, agreeing that, if delivery was not possible, he would accept the repayment of the advance with interest at 8% per annum.
The defendants eventually opted to discharge their obligation by returning the sum advanced, coupled with interest.
They offered repayment by tendering the money, and when the plaintiff refused to accept the tender, they deposited or consigned P6,500 with the clerk of the Court of First Instance.
Before the trial commenced, the plaintiff unconditionally withdrew the consigned money, a move interpreted as acceptance of the alternative discharge.

The contract provided the defendants an alternative means to discharge their obligation: either by delivering the sugar or by refunding the money advanced with interest.
The plaintiff’s subsequent actions—especially his unreserved acceptance by withdrawing the consigned money—played a crucial role in the resolution of the dispute.

Whether the additional clauses purporting to alter the repayment conditions were validly inserted or void due to the lack of the plaintiff’s knowledge and consent.
Whether the defendants’ offer to repay the sum advanced, along with the interest, constituted a valid alternative discharge of their contractual obligations.
Whether the plaintiff’s withdrawal of the consigned money, unconditionally and without reservation, amounted to a waiver of any further claims against the defendants under the contract.
Whether the contractual provision allowing for alternative performance should be interpreted as fulfilling the entire obligation, thereby negating the plaintiff’s claim for additional damages.