Case Digest (G.R. No. 225007)
Facts:
San Miguel Foods, Inc. and James A. Vinoya v. Ernesto Raoul V. Magtuto, G.R. No. 225007, July 24, 2019, Supreme Court Second Division, Carpio, J., writing for the Court.Respondent Ernesto Raoul V. Magtuto was a broiler chick grower who attended a July 2002 gathering of growers organized by Swift Foods, Inc.; present as representatives of San Miguel Foods, Inc. (SMFI) were Dr. James A. Vinoya, SMFI’s veterinarian and production supervisor, and Engr. Rene C. Ogilvie, SMFI’s Bicol Region Poultry Operations Manager. Several months later (September 2002) Vinoya and Magtuto agreed—verbally and without a written contract—that SMFI would supply day‑old chicks, feeds, medicines and technical support and that Magtuto would grow batches of chicks (36,000 per “grow”) and be paid a grower’s fee; Magtuto posted a P72,000 cash bond as security.
From October/November 2002 through April 2003 SMFI delivered chicks to Magtuto four times and paid grower’s fees after each harvest. On the fifth delivery in June 2003 SMFI delivered only 32,000 chicks (4,000 short). After exchanges with Vinoya and a complaint to Ogilvie, Magtuto received notice (12 August 2003) that the arrangement was terminated for “poor working relationship.” Magtuto alleged he suffered lost income, out‑of‑pocket expenses and injury to reputation, and filed Civil Case No. 2004‑0008 before the Regional Trial Court (RTC), Naga City, Branch 22.
The RTC (Decision dated February 4, 2013) found a contract existed despite lack of writing, held SMFI and Vinoya jointly and severally liable, and awarded actual/compensatory, moral, nominal and exemplary damages plus attorney’s fees. SMFI appealed. The Court of Appeals (CA) in a Decision dated August 28, 2015 modified the RTC: it increased the award for actual/compensatory damages (to PhP383,835.85) but deleted awards for moral, exempla...(Subscriber-Only)
Issues:
- Whether the appellate court committed reversible error in holding that Magtuto is entitled to actual or compensatory damages absent a written broiler chicken contract growing agreement between Magtut...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)