Case Digest (G.R. No. 156819) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In July 2002, Ernesto Raoul V. Magtuto, a prominent broiler chick grower in Camarines Sur doing business as Alyssandra Farms, attended a gathering of Swift Foods, Inc. growers at Villa Caceres Hotel in Naga City, where he met representatives of San Miguel Foods, Inc. (SMFI)—Dr. James A. Vinoya and Engr. Rene C. Ogilvie. Although no written contract was executed, Vinoya agreed to “accommodate” Magtuto as an SMFI contract grower whenever excess day-old chicks were available from SMFI’s Laguna hatchery. Under their verbal agreement, SMFI would deliver 36,000 chicks per batch, supply feeds, medicines, materials, and technical support, harvest the grown birds after 30–35 days, and pay Magtuto a grower’s fee, while Magtuto posted a ₱72,000 cash bond to guarantee performance. Between October 2002 and April 2003, Magtuto successfully managed four batches, but in June 2003 SMFI delivered only 32,000 chicks. After Magtuto’s protests and a complaint letter against Vinoya’s conduct, SMFI te Case Digest (G.R. No. 156819) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and parties
- Ernesto Raoul V. Magtuto (respondent) was a broiler chick grower under Swift Foods, Inc. until its Bicol operations closed in 2002.
- San Miguel Foods, Inc. (SMFI) is a poultry integrator; Dr. James A. Vinoya (petitioner) was SMFI’s veterinarian and production supervisor in Bicol.
- Formation and performance of the oral agreement
- At a growers’ meeting in July 2002, SMFI representatives (Vinoya and Engr. Rene C. Ogilvie) pitched SMFI’s contract-growing scheme to local growers, including Magtuto.
- In September 2002, Magtuto and Vinoya agreed orally (without a signed contract) that SMFI would deliver 36,000 day-old chicks per “grow,” supply feeds, medicines and technical support, harvest the grown chickens, and pay Magtuto a grower’s fee. Magtuto posted a P72,000 cash bond.
- From October 2002 to April 2003, SMFI delivered chicks and performed harvests four times; Magtuto received the corresponding grower’s fees.
- Dispute and procedural history
- On the fifth delivery in June 2003, SMFI delivered only 32,000 chicks. Magtuto complained, but SMFI treated the arrangement as a mere accommodation and terminated it for “poor working relationship.”
- Magtuto filed suit for damages (actual, moral, nominal, exemplary), return of bond, and attorney’s fees.
- The Regional Trial Court (RTC) held that a valid oral contract existed and awarded various damages. The Court of Appeals (CA) affirmed with modification, deleting non-pecuniary damages and increasing actual damages. SMFI appealed to the Supreme Court.
Issues:
- Primary issue
- Whether Magtuto is entitled to actual or compensatory damages for the short delivery of chicks in the absence of a written broiler chicken contract growing agreement with SMFI.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)