Case Digest (G.R. No. 141525)
Facts:
Carlos Sanchez v. Medicard Philippines, Inc., Dr. Nicanor Montoya and Carlos Ejercito, G.R. No. 141525, October 9, 2006, the Supreme Court Third Division, Sandoval-Gutierrez, J., writing for the Court.In 1987, Medicard Philippines, Inc. appointed Carlos Sanchez (petitioner) as its special corporate agent, giving him commissions based on the "cash brought in." Through petitioner’s efforts in September 1988, Medicard and United Laboratories Group of Companies (Unilab) executed a one-year Health Care Program Contract under which Unilab paid Medicard a premium of P4,148,005.00; Medicard paid petitioner 18% (P746,640.90) as commission. The contract was renewed for October 1, 1989 to September 30, 1990 with an increased premium of P7,456,896.00, and Medicard paid petitioner P1,342,241.00 as commission.
Before the renewed contract expired, Medicard — through petitioner — proposed a further premium increase for the next year, but Unilab rejected it as too high. Medicard’s president, Dr. Nicanor Montoya (respondent), asked petitioner to reduce his commission on any renewal, but petitioner refused. On October 3, 1990, Unilab, through Carlos Ejercito (respondent), informed Medicard it would not renew the premium-based contract.
To avoid prejudicing its personnel, Unilab negotiated directly with Medicard officers (including Dr. Montoya) a new arrangement: a "cost-plus" scheme under which Unilab would pay actual hospitalization expenses plus a 15% service fee (not less than P780,000.00). Under this new scheme Medicard did not give petitioner any commission. Petitioner demanded payment of P338,000.00 plus damages by letter dated March 15, 1991; Medicard refused.
Petitioner filed a complaint for sum of money against Medicard, Dr. Montoya and Ejercito in the Regional Trial Court (RTC), Branch 66, Makati City. After trial the RTC dismissed the complaint and respondents’ counterclaim. On appeal the Court of Appeals (CA) in CA-G.R. CV No. 47681 affirmed t...(Pro-only)
Issues:
- Was the agency contract between Medicard and Sanchez revoked such that Sanchez is not entitled to commission?
- If revocation did not occur, was Sanchez nonetheless the procuring cause or otherwise entitled to a commis...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)