Case Digest (G.R. No. 196158)
Facts:
This is Magna Ready Mix Concrete Corporation v. Andersen Bjornstad Kane Jacobs, Inc., G.R. No. 196158, promulgated January 20, 2021, decided by the Supreme Court Third Division, Hernando, J., writing for the Court. The petition for review on certiorari under Rule 45 sought review of the Court of Appeals’ September 8, 2010 Decision and March 14, 2011 Resolution in CA‑G.R. CV No. 92647, which affirmed with modifications the Regional Trial Court (RTC), Branch 161, Pasig City’s August 19, 2008 Decision in Civil Case No. 69953.Petitioner Magna Ready Mix Concrete Corporation (MAGNA) is a Philippine corporation; respondent Andersen Bjornstad Kane Jacobs, Inc. (ANDERSEN) is a Washington State (U.S.) corporation. ANDERSEN sued MAGNA on April 20, 2004 for collection of an unpaid balance alleged to be US$60,786.59 arising from professional services (design, plant development, consultation) provided pursuant to a purchase order (October 21, 1996) and an Agreement for Professional Services dated November 29, 1996. ANDERSEN alleged it was suing on an isolated transaction and admitted it had no license to do business in the Philippines.
MAGNA admitted contracting with ANDERSEN but disputed liability for certain claimed services and contended the contract was executed after the services were performed. MAGNA later moved to dismiss, asserting that ANDERSEN was actually doing business in the Philippines without the required license—a fact MAGNA claimed it discovered during trial because ANDERSEN had filed another suit against a different Philippine corporation relating to other transactions. The RTC denied MAGNA’s motion to dismiss (March 19, 2007) on estoppel grounds and proceeded to trial.
The RTC (Aug. 19, 2008) found a binding contract and that ANDERSEN rendered services even prior to formal execution; it awarded ANDERSEN US$35,694.03, 12% interest from filing of the complaint, P50,000 attorney’s fees, and costs. Both parties appealed. The Court of Appeals (Sept. 8, 2010) modified the RTC judgment, awarding the full US$60,786.59, 12% legal interest from extrajudicial demand dated June 26, 1998, exemplary damages of P30,000, and attorney’s fees of P50,000; MAGNA’s motion for reconsideration was denied (Mar. 14, 2011).
MAGNA then filed the present Rule 45 petition (filed May 6, 2011) raising primarily whether ANDERSEN had legal capacity to sue in the Philippines because it was do...(Subscriber-Only)
Issues:
- Does Andersen Bjornstad Kane Jacobs, Inc. have legal capacity to sue in the Philippines despite not being licensed to do business ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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