Case Digest (G.R. No. 96505)
Facts:
In Legaspi Oil Co., Inc. v. Court of Appeals and Bernard Oseraos (G.R. No. 96505, July 1, 1993), petitioner Legaspi Oil Co., Inc. (then appellee) and private respondent Bernard Oseraos (then defendant) entered into successive contracts for the sale of copra between May 1975 and March 1976. Each contract, negotiated through Oseraos’s agents, fixed varying prices “per 100 kilos” based on market rates at the time. On February 16, 1976, contract No. 3804 bound Oseraos to deliver 100 metric tons of copra at P82.00 per 100 kilos within 20 days. He delivered only 46,334 kilos, leaving an outstanding balance of 53,666 kilos. After repeated demands and a final warning letter dated October 6, 1976, petitioner purchased the undelivered balance on the open market at P168.00 per 100 kilos, suffering a price differential loss of P46,152.76. Petitioner then filed Civil Case No. 5529 before the CFI of Albay, which awarded P48,152.76 in damages (including attorney’s fees and costs). On appeal, t...Case Digest (G.R. No. 96505)
Facts:
- Parties and contract history
- Petitioner Legaspi Oil Co., Inc. purchased copra from respondent Bernard Oseraos through authorized agents at fluctuating market prices in 1975–1976.
- Notable contracts: May 27, 1975 (70 tons at ₱95/100 kg); Sept 23, 1975 (30 tons at ₱102/100 kg); Nov 6, 1975 (100 tons at ₱79/100 kg); Feb 16, 1976 (100 tons at ₱82/100 kg, delivery within 20 days from March 8, 1976).
- Breach and remedial measures
- Respondent delivered only 46,334 kg of the contracted 100,000 kg, leaving 53,666 kg undelivered.
- After repeated demands and a final warning letter dated October 6, 1976, petitioner purchased the undelivered balance on October 22, 1976 at the open-market price of ₱168/100 kg, suffering a price differential loss of ₱86/100 kg, or ₱46,152.76.
- Procedural posture
- Trial court (Civil Case No. 5529, CFI of Albay) found respondent liable for damages of ₱48,152.76, attorney’s fees of ₱2,000, and litigation costs.
- Court of Appeals (CA-G.R. CV No. 05828) reversed and dismissed the complaint on March 23, 1990.
- Petitioner filed a petition for review on certiorari before the Supreme Court.
Issues:
- Main issue
- Is respondent Oseraos liable for damages arising from fraud or bad faith in deliberately breaching the copra sales contract?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)