Case Digest (G.R. No. L-10104) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In April 1994, petitioner Tomasa Sarmiento accepted an assignment from her friend, Dra. Virginia Lao, to have a pair of diamond earrings reset into two gold rings. Sarmiento sent an intermediary, Tita Payag, with the earrings to Dingdingas Jewelry Shop, owned and managed by spouses Luis and Rose Sun-Cabrido and assisted by their goldsmith, Zenon Santos, in Tagbilaran City. For a P400 job order and provision of 12 grams of gold, the shop agreed to craft the new settings. When Marilou Sun, another respondent, attempted to dismount one diamond, she enlisted Santos, who used pliers instead of the customary wire saw, thereby breaking the gem. After respondents refused to replace the diamond, Sarmiento purchased a substitute at P30,000. She filed Civil Case No. 2339 before the Municipal Trial Court in Cities (MTCC) of Tagbilaran City on June 28, 1994, which rendered judgment awarding P30,000 actual damages, P3,000 moral damages, P5,000 attorney’s fees, and P2,000 litigation expenses a Case Digest (G.R. No. L-10104) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Transaction
- In April 1994, Petitioner Tomasa Sarmiento was requested by Dr. Virginia Lao to reset a pair of diamond earrings into two gold rings. She provided 12 grams of gold and paid P400 to Dingdingas Jewelry Shop, owned and managed by spouses Luis and Rose Sun-Cabrido.
- Petitioner sent her representative, Tita Payag, to the shop to deliver the earrings and finalize the job order.
- Dismounting and Breakage of Diamond
- Three days later, Payag returned one .33-carat diamond earring; respondent Maria Lourdes (Marilou) Sun attempted to dismount it but referred the task to goldsmith Zenon Santos.
- Santos used pliers instead of the customary wire saw, causing the diamond to fracture. Upon respondents’ refusal to replace it, Petitioner purchased a replacement at P30,000 and demanded reimbursement.
- Denials and Judicial Proceedings
- Rose Cabrido denied any transaction with Payag; Marilou admitted knowing Payag but denied accepting the job; Santos claimed to be an independent worker.
- After unsuccessful barangay mediation, Petitioner filed Civil Case No. 2339 (MTCC, Tagbilaran City) and won P30,000 compensatory, P3,000 moral, P5,000 attorney’s fees, and P2,000 litigation expenses. The RTC reversed; the CA affirmed; Petitioner elevated the case to the Supreme Court.
Issues:
- Employment Status and Vicarious Liability
- Whether goldsmith Zenon Santos was an employee of Dingdingas Jewelry Shop under Labor Code Article 280, thus rendering respondents vicariously liable for his negligence.
- Scope of Contractual Obligation
- Whether the verbal contract to craft gold rings mounted with diamonds included the dismounting of the stones from their original settings, making respondents liable for breakage.
- Entitlement to Damages
- Whether Petitioner is entitled to actual and moral damages due to respondents’ negligence or gross neglect in performing the contractual service.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)