Case Digest (G.R. No. 125761)
Facts:
Salvador P. Malbarosa v. Hon. Court of Appeals and S.E.A. Development Corp., G.R. No. 125761, April 30, 2003, Supreme Court Second Division, Callejo, Sr., J., writing for the Court.The petitioner, Salvador P. Malbarosa, was president and general manager of Philtectic Corporation and an officer in other companies in the S.E.A. Development Corporation (SEADC) group. SEADC assigned to Malbarosa a 1982 Mitsubishi Galant (plate PCA 180) and issued him membership certificates in the Architectural Center, Inc. On January 8, 1990 Malbarosa tendered his resignation effective February 28, 1990 and requested payment of his 1989 incentive compensation.
On March 14, 1990 SEADC, through Vice-Chairman Senen Valero, sent Malbarosa a written letter-offer stating SEADC accepted his resignation and offering an incentive compensation of P251,057.67 to be satisfied by transferring the car (valued at P220,000) and certain membership shares (approx. P60,000); the letter required that acceptance be manifested by affixing signature and the date in the space marked "Agreed." On March 16, 1990 Louis Da Costa handed the original letter-offer to Malbarosa for his consideration; Malbarosa refused to sign and kept the original for review, marking the duplicate “Recd original for review purposes.” He later claimed to have signed the original on March 28, 1990 but did not transmit it to SEADC until he sent a copy on April 7, 1990.
Because the original offer remained unsigned and unreturned, SEADC resolved on April 3, 1990 to demand return of the car and to institute recovery proceedings; Philtectic Corporation, by letter dated April 4, 1990, withdrew the March 14 offer and demanded return of the car within 24 hours. SEADC filed a complaint for recovery of personal property with replevin; the trial court issued a writ of replevin (May 8, 1990) and the sheriff initially took possession (May 11, 1990) but Malbarosa regained possession by posting a counter-bond (May 15, 1990).
At trial Malbarosa argued he had accepted the March 14 offer (signed March 28, 1990) and that Philtectic lacked authority to withdraw SEADC’s offer. The Regional Trial Court (Pasig, Branch 158) rendered judgment July 28, 1992 ordering Malbarosa to deliver the vehicle or pay its value of P220,000, and to pay P50,000 attorneys’ fees and costs; on October 10, 1992 the trial court amended its dispositive order to award rentals at P1,000 per day from May 8, 1990 until delivery and to hold the bonding company liable under the counterbond.
The petitioner appealed to ...(Pro-only)
Issues:
- Was there a valid acceptance by Malbarosa of SEADC’s March 14, 1990 letter-offer such that a contract was perfected?
- Was the April 4, 1990 withdrawal of the March 14, 1990 letter-offer (made by Philtectic Corporation) effecti...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)