Case Digest (G.R. No. 196158) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Magna Ready Mix Concrete Corporation vs. Andersen Bjornstad Kane Jacobs, Inc. (G.R. No. 196158, January 20, 2021), petitioner Magna Ready Mix Concrete Corporation (MAGNA), a Philippine corporation, was sued by respondent Andersen Bjornstad Kane Jacobs, Inc. (ANDERSEN), a Washington‐state corporation, for collection of US$60,786.59 plus interest, exemplary damages, and attorney’s fees. Andersen alleged that in 1996 it entered into an Agreement for Professional Services with Magna (purchase order dated October 21, 1996; contract dated November 29, 1996) to perform design, consultation, and inspection services for a precast plant, PIC double‐tee form design, and the Ecocentrum Garage preliminary design. Andersen partially rendered services and demanded payment by extrajudicial demand on June 26, 1998, but Magna left a balance of US$60,786.59 unpaid. Andersen filed its complaint on April 20, 2004 in the Regional Trial Court (RTC), Branch 161, Pasig City. Magna denied liability, c Case Digest (G.R. No. 196158) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Complaint
- Petitioner Magna Ready Mix Concrete Corporation (MAGNA), Philippine corporation; Respondent Andersen Bjornstad Kane Jacobs, Inc. (ANDERSEN), Washington State corporation.
- ANDERSEN filed on April 20, 2004 a complaint for collection of US$60,786.59, plus interest, exemplary damages and attorney’s fees, alleging partial nonpayment for professional services.
- Contractual Engagements and Alleged Services
- October–November 1996: MAGNA issued purchase order and executed Agreement for Professional Services with ANDERSEN for precast plant design, PIC double tee form design, and Ecocentrum Garage preliminary design.
- February 1997: ANDERSEN prepared and delivered preliminary designs; MAGNA made partial payments leaving US$60,786.59 unpaid.
- Procedural History
- RTC, Branch 161 Pasig City (Aug. 19, 2008 Decision): Found a binding contract; awarded US$35,694.03 with 12% interest from complaint filing, P50,000 attorney’s fees, costs (deducted alleged SPI equity participation).
- CA (Sept. 8, 2010 Decision; Mar. 14, 2011 Resolution): Affirmed with modifications; awarded full US$60,786.59 with 12% interest from June 26, 1998 demand, exemplary damages P30,000, attorney’s fees P50,000.
- SC Petition (G.R. No. 196158): Challenges CA’s findings, raising legality of ANDERSEN’s capacity to sue and other factual issues.
Issues:
- Whether ANDERSEN, a foreign corporation, had legal capacity to sue in the Philippines for the disputed contract.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)