Case Digest (G.R. No. 232688) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mazda Quezon Avenue v. Caruncho, decided on April 26, 2021 under G.R. No. 232688, petitioner Mazda Quezon Avenue sold respondent Alexander Caruncho a brand-new 2011 Mazda 6 sedan on January 12, 2011. One week after delivery, Caruncho detected a persistent knocking and rattling sound under the hood. He immediately sought a full refund, but Mazda’s General Manager refused and promised to repair the defect free of charge. Technicians identified a faulty rack and pinion mechanism—an integral steering component—and undertook five replacements during the vehicle’s three-year warranty period. Despite these efforts, the noise persisted. On February 19, 2014, a final test drive by Mazda personnel confirmed the defect remained unresolved, prompting Caruncho to demand reimbursement of the purchase price plus consequential damages. When negotiations failed, he filed a Complaint on July 31, 2014 with the Department of Trade and Industry (DTI) Consumer Assistance and Protection Division. I Case Digest (G.R. No. 232688) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Sale and Defect
- On January 12, 2011, Alexander Caruncho purchased a brand-new 2011 Mazda 6 sedan from Mazda Quezon Avenue.
- Within one week, he heard a persistent knocking and rattling sound from under the hood.
- Warranty and Repair Attempts
- Mazda’s General Manager refused a refund but promised to fix the defect. Road tests revealed a defective rack and pinion mechanism. Mazda assured replacement after the first 1,000-km check-up.
- During the three-year warranty period, Mazda replaced the rack and pinion mechanism five times; the noise persisted despite each replacement.
- Administrative and Judicial Proceedings
- On July 31, 2014, Caruncho filed a complaint with the DTI Consumer Assistance and Protection Division.
- The DTI Adjudication Officer (Dec. 1, 2014) and the DTI Appeals Committee (Jan. 8, 2015) found Mazda liable under Republic Act No. 7394 (Consumer Act), ordering either replacement or refund, plus fines.
- Mazda sought certiorari relief from the Court of Appeals, which dismissed the petition (Apr. 3, 2017) and denied reconsideration (July 6, 2017).
- Mazda elevated the case to the Supreme Court by petition for review.
Issues:
- Whether Mazda is liable under the Consumer Act for selling a vehicle with an uncorrected defect that renders it unfit for its intended use.
- Whether Caruncho’s action had prescribed under the Consumer Act’s two-year prescription rule.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)