Case Digest (G.R. No. 152219)
Facts:
Nutrimix Feeds Corporation v. Court of Appeals and Spouses Efren and Maura Evangelista, G.R. No. 152219, October 25, 2004, the Supreme Court Second Division, Callejo, Sr., J., writing for the Court.
Petitioner Nutrimix Feeds Corporation (Nutrimix) sold assorted animal feeds to respondents Spouses Efren and Maura Evangelista, who purchased on credit with postdated checks and a thirty- to forty-five-day credit accommodation. Deliveries occurred in mid‑1993 and, although respondents initially paid, unpaid invoices and several dishonored postdated checks resulted in an aggregate unpaid balance of P766,151.00. When respondents’ depository account was already closed, several checks were dishonored. Nutrimix demanded payment but respondents failed to settle.
On December 15, 1993 Nutrimix filed Civil Case No. 1026‑M‑93 in the Regional Trial Court (RTC) of Malolos, Bulacan (Branch 9) for sum of money and damages with prayer for preliminary attachment. The respondents answered, admitted indebtedness but alleged that many of their broilers and hogs died from feeds supplied by Nutrimix; they counterclaimed that the feeds were contaminated. On January 19, 1994 respondents separately filed Civil Case No. 49‑M‑94 for damages for the alleged contaminated feeds; the trial court later consolidated the two cases.
At trial, Nutrimix presented one witness; respondents produced several expert witnesses and laboratory reports. Respondents testified that massive deaths of broilers occurred after feeding on Nutrimix feeds delivered on July 26–27, 1993. Laboratory examinations performed in October 1993 on feed samples submitted by respondents yielded mixed results: absence of salmonella, very high aflatoxin readings, cytogenetic findings on test chickens, and detection of anticoagulant rodenticide compounds (Coumatetralyl/Warfarin) in certain samples; some experts, however, could not verify that the tested samples were identical to the feeds actually fed to the dead fowls.
The RTC, after evaluating the evidence, ruled for Nutrimix: it found insufficient proof that the feeds were contaminated when leaving Nutrimix’s control, suggesting contamination could have occurred after delivery, and dismissed Civil Case No. 49‑M‑94 while ordering respondents to pay Nutrimix P766,151.00 with interest and attorneys’ fees in Civil Case No. 1026‑M‑93 (RTC decision dated January 12, 1998).
The respondents appealed to the Court of Appeals (CA). On February 12, 2002 the CA, in CA‑G.R. CV No. 59615, modified the RTC decision by dismissing Nutrimix’s complaint in Civil Case No. 1026‑M‑93 for lack of merit and holding that Nutrimix breached the warranty against hidden defects, thereby relieving respondents of the payment obligation.
...(Pro-only)Issues:
- May the Supreme Court review the Court of Appeals’ factual findings under a Rule 45 petition on certiorari?
- Was there sufficient proof that Nutrimix breached the warranty against hidden defects such that respondents were excused from paying their outst...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
- (Pro-only)