Title
King Mau Wu vs. Sycip
Case
G.R. No. L-5897
Decision Date
Apr 23, 1954
Plaintiff King Mau Wu sued defendant Francisco Sycip for unpaid commissions under an agency agreement for the sale of coconut oil. Court ruled in favor of plaintiff, awarding commissions, overprice share, and interest.

Case Digest (G.R. No. L-5897)
Expanded Legal Reasoning Model

Facts:

  • Parties Involved
    • Plaintiff: King Mau Wu, acting as agent in the sale of Philippine coconut oil and its derivatives.
    • Defendant: Francisco Sycip, the principal with whom the agency agreement was executed.
  • The Agency Agreement and Its Terms
    • An agency contract was established by a letter dated 7 November 1946 in New York, which was accepted by the defendant on 22 November 1946.
    • Under the agreement, the plaintiff was appointed as the exclusive agent for selling coconut oil and its derivatives outside the Philippines.
    • The compensation clause stipulated a commission of 2½ per cent on the total actual sale price obtained through the plaintiff’s efforts, plus an additional 50 per cent of the difference between the authorized sale price and the actual selling price, whenever such a favorable difference existed.
  • The Transaction at Issue
    • The transaction involved the sale of 1,000 metric tons of coconut oil emulsion, executed on a free on board (f.o.b.) basis in Manila.
    • The coconut oil emulsion was sold by the plaintiff (as agent of the defendant) to Jas. Maxwell Fassett, who then assigned his rights under a letter of credit to Fortrade Corporation.
    • A letter of credit (No. 20112 by the Chemical Bank & Trust Company) was established in favor of Jas. Maxwell Fassett, underpinning the transaction.
  • Evidence and Correspondence Submitted
    • Multiple drafts and letters prepared by Jas. Maxwell Fassett, which led up to the execution of the formal agency agreement, were submitted.
    • Key letters and communications include:
      • A letter dated 2 January 1947 that referred directly to the transaction of the 1,000 metric tons and confirmed commission arrangements.
      • A letter of 16 January 1947 wherein the defendant reiterated commission arrangements and mentioned adjustments due to cost increases in production.
      • A telegram from the defendant acknowledging the plaintiff’s role and entitlements.
    • Additional documents later introduced included:
      • A duplicate original of a letter dated 16 October 1946, purportedly related to the sale.
      • The letter of credit No. 20122 from the Chemical Bank & Trust Company.
      • A letter dated 16 December 1946 from Fortrade Corporation placing a firm order for 1,000 metric tons, and subsequent acceptance on 24 December 1946.
  • Post-Trial Proceedings and Movements
    • At trial, the depositions of the plaintiff, Jas. Maxwell Fassett, and other longhand evidences (including the sequence of letters) supported the plaintiff’s claim for commission, overprice, and interest.
    • The trial court rendered judgment in favor of the plaintiff awarding the claimed sums (P7,589.88 for commission, P50,000 for half of the overprice, plus interest from 14 October 1947, and costs).
    • Subsequent procedural moves by the defendant, including a motion for reconsideration and a motion for new trial (based on newly discovered evidence), were both denied.
    • The defendant then appealed the trial court’s judgment.

Issues:

  • Whether the sale of 1,000 metric tons of coconut oil emulsion was legitimately covered by the agency agreement executed on 7 November 1946 (accepted 22 November 1946) or if it constituted an independent transaction.
  • Whether the evidence, including various letters and correspondences, clearly establishes the commission arrangements and confirms that the transaction was not separate from the agency agreement.
  • Whether the defendant’s contention—that the transaction was agreed upon on 16 October 1946 and should be treated as an independent contract—has merit under the evidence presented.
  • Whether the proper jurisdiction for the enforcement of this contractual dispute lies with the courts of Manila, considering the non-resident status of the defendant and the fact that the contract was executed abroad.
  • Whether the newly discovered evidence, which the defendant argued could change the outcome, was indeed material enough to warrant a new trial.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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