Case Digest (G.R. No. 116682)
Facts:
Roblett Industrial Construction Corporation v. Court of Appeals and Contractors Equipment Corporation, G.R. No. 116682, January 02, 1997, the Supreme Court First Division, Bellosillo, J., writing for the Court.Petitioner Roblett Industrial Construction Corporation (RICC) contracted in 1985 to lease construction equipment from respondent Contractors Equipment Corporation (CEC) and allegedly accumulated unpaid rental charges. On 19 December 1985 RICC, through its Assistant Vice President for Finance Candelario S. Aller Jr., executed an Agreement with CEC (Exh. A/I) that confirmed the account; as part of an offset arrangement RICC delivered construction materials worth P115,000.00, reducing the stated balance to P227,909.38.
A day earlier, 18 December 1985, RICC delivered P10,000.00 in postdated checks to CEC which were subsequently dishonored; CEC debited those returned checks to RICC’s account, raising the balance to P237,909.38. On 24 July 1986 CEC’s general manager sent a letter of demand for P237,909.38, giving RICC until 31 July 1986 to settle; RICC asked for thirty days to obtain funds.
In the trial court RICC contested the Agreement’s validity and asserted it had actually overpaid by about P12,000.00 based on Equipment Daily Time Reports covering 2 May to 14 June 1985 (191 hours). CEC countered with a statement of account covering 28 March to 12 July 1985 showing a total of P376,350.18, from which payments left a balance reflected in the Agreement. On 19 December 1990 the Regional Trial Court (Makati) rendered judgment ordering RICC to pay P237,909.38 plus legal interest from 31 July 1986, P2,000 litigation expenses, 20% attorney’s fees and costs, the trial court finding the Agreement valid, treating RICC’s unsworn answer as an admission (Section 8, Rule 8, Rules of Court), and rejecting RICC’s partial daily reports as incomplete.
On 29 July 1994 the Court of Appeals, in a decision penned by Justice Guingona (with Justices Paras and Verzola concurring), affirmed the trial court’s decision. RICC then filed a petition for review with the Supreme Court under Rule 45 challenging chiefly the factual f...(Subscriber-Only)
Issues:
- Procedural: May petitioner raise for the first time before the Supreme Court the alleged invalidity or lack of authority to execute the Agreement when it limited its assignment of errors to the single issue of full payment before the Court of Appeals?
- Substantive: Was the Agreement enforceable and did the evidence show that petitioner had fully paid respondent or overpaid respond...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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