Case Digest (G.R. No. 258486)
Facts:
Mary Ann Carmen Ferrer, in her capacity as Attorney-in-Fact of M.Y. Intercontinental Trading Corporation and/or Tedwin T. Uy, G.R. No. 258486, August 02, 2023, Supreme Court Second Division, Lopez, J., writing for the Court. The petition for review on certiorari challenges the Court of Appeals' reversal of the Regional Trial Court's declaration that the transaction between the parties was a contract of sale and that petitioners were unpaid sellers.The dispute arises from a 2008 contract between St. Mary’s Publishing and Fujian New Technology Color Marking and Printing Company (a Chinese printing firm), with Fujian being represented locally by M.Y. Intercontinental Trading Corporation (M.Y. Intercontinental), where Tedwin T. Uy served as Senior Executive Vice-President. Under the Contract, St. Mary’s issued an Authority to Print, a December 7, 2009 Purchase Order and sub-purchase orders; pursuant to the Purchase Order Fujian printed 91,000 copies of Pagpapaunlad ng Kasanayan sa Pagbasa and 210,000 copies of Developing Reading Power at a printing cost of PHP 11,347,781.08.
When St. Mary’s failed to pay for the printed textbooks, M.Y. Intercontinental issued a notice of rescission of the December 7, 2009 Purchase Order. M.Y. Intercontinental, through its attorney-in-fact Marie Ann Carmen F. Ferrer, then filed a Petition for Declaratory Relief (Civil Case No. MC-10-5078) against St. Mary’s Publishing and its Senior Executive Vice President Jerry Vicente S. Catabijan, asserting the transaction was a contract of sale and that Fujian/M.Y. Intercontinental were unpaid sellers entitled to remedies under the Civil Code (lien, resale, rescission).
The Regional Trial Court, Branch 213, Mandaluyong City, granted the Petition and declared the agreement a contract of sale, ruled that petitioner was an unpaid seller within the meaning of Article 1526 of the New Civil Code and awarded the possessory lien, right to resale, and right to rescind; it also invoked the first-sale doctrine and validated documentary proof. The RTC denied respondents’ motion for reconsideration.
Respondents appealed to the Court of Appeals (CA-G.R. CV No. 110189). On January 6, 2021, the Court of Appeals reversed and set aside the RTC decision and dismissed the Petition for Declaratory Relief, holding that an action for declaratory relief is no longer available because the contract had already...(Pro-only)
Issues:
- Is a petition for declaratory relief the proper recourse in this case? ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)