Title
La Fuerza, Inc. vs. Court of Appeals
Case
G.R. No. L-24069
Decision Date
Jun 28, 1968
A dispute arose when La Fuerza refused to pay for a defective conveyor system installed by Associated Engineering. The Supreme Court ruled La Fuerza's rescission claim was barred by the six-month prescriptive period, favoring the plaintiff.

Case Digest (G.R. No. L-24069)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The dispute arose from an ordinary action for the recovery of a sum of money relating to the installation of flat belt conveyors.
    • The plaintiff, Associated Engineering Co., Inc., is engaged in the manufacture and installation of such conveyors, while the defendant, La Fuerza, Inc., is primarily a wine manufacturer.
  • Formation of the Contract
    • In January 1960, Antonio Co, the technical manager and engineer for the plaintiff, visited La Fuerza’s office and plant.
    • He noted the need for a conveyor system to facilitate the movement of empty bottles from the storage room to the production area and offered his services to manufacture and install the system.
    • Upon the suggestion of Mariano Lim, the defendant’s president and general manager, Antonio Co put his offer in writing on February 4, 1960 (Exhibit A).
    • On February 11, 1960, Mariano Lim indicated his conformity by signing the offer beneath the word “confirmation,” while adding a note that all specifications must strictly follow an approved plan attached to the agreement.
  • Contract Performance and Execution
    • The plaintiff began preparing the premises by digging holes for the installation and invoiced the defendant for a total contract price of P13,250.00.
    • A down payment of P5,000.00 was rendered by the defendant, leaving a balance of P8,250.00 to be paid upon completion of the installation (Exhibit B).
    • The installation proceeded during March and April 1960, with trial runs conducted in May, June, and July 1960.
    • Despite repeated calls for necessary adjustments after several trial runs displayed functional deficiencies—such as bottles colliding, falling off, and inefficient transport—the faults in the conveyor system were not corrected to the satisfaction of the defendant.
  • Dispute and Subsequent Litigation
    • Believing the installed conveyors did not fulfill their intended purpose, the defendant refused to pay the remaining balance.
    • Consequently, on March 22, 1961, the plaintiff initiated an action to recover the balance of P8,250.00 along with additional attorney’s fees and costs.
    • In its answer, La Fuerza counterclaimed alleging that the conveyors failed to meet the conditions and warranting quality, seeking rescission of the contract and a refund of the P5,000.00 down payment, plus attorney’s fees.
  • Procedural History
    • The Court of First Instance of Manila initially rendered a decision rescinding the contract, ordering the plaintiff to refund the P5,000.00 down payment and permit removal of the conveyors.
    • The Court of Appeals affirmed that decision but subsequently, on motion for reconsideration by the plaintiff, set aside its original decision and reversed the outcome, ordering La Fuerza to pay the balance with interest and additional costs.
    • La Fuerza petitioned for review on certiorari, contesting the view that the six-month prescription period under Article 1571 of the Civil Code barred its action for rescission.

Issues:

  • Whether the installation and operation of the conveyors by the plaintiff constituted a completed delivery, irrespective of the defendant’s explicit acceptance or rejection.
    • Determining if the placement of the conveyors under the defendant’s control is sufficient to trigger delivery under Article 1497 of the Civil Code.
  • Whether the defendant’s action for rescission of the contract was timely given the prescription period stipulated in Article 1571 which bars action after six months from the delivery of the thing sold.
    • Analysis of whether the “delivery” in this context refers merely to control and possession or requires formal acceptance by the defendant.
  • Whether the purported delay (over ten months after installation) in seeking rescission by La Fuerza is legally justifiable under the specific provisions on warranty against hidden defects and rescission in contracts for sales.
    • The precise interpretation of Article 1571 in relation to sales versus contracts for work or piece installations.
  • Whether the separate acts of delivery by the vendor and acceptance by the vendee play distinct roles in determining the commencement of the prescription period for actions based on hidden defects.
    • Clarification of the legal distinction between delivery and acceptance as defined in the Civil Code and their implications in this case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.