Case Digest (G.R. No. 74027) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In October, November, and December 1975, Gregorio de Leon, doing business as Mark Industrial Sales, sold and delivered various merchandise items to Silahis Marketing Corporation under several invoices totaling ₱22,213.75, each payable within thirty days. When Silahis failed to settle the account despite repeated demands, de Leon filed a complaint in the Court of First Instance of Manila on July 1, 1976, seeking collection of the principal, accrued interest of ₱661.03, attorney’s fees of ₱5,000.00, and litigation costs. In its answer, Silahis admitted receipt of the goods but raised two affirmative defenses: first, a debit memo for ₱22,200.00 representing alleged unrealized profit or commission on a direct sale of sprockets worth ₱111,000.00 to Dole Philippines, Inc., which bypassed Silahis in violation of their usual arrangement; and second, a claim for cancellation of ₱6,000.00 relating to a defective stainless steel screen returned by its client, Borden International of Davao Case Digest (G.R. No. 74027) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Transaction
- Silahis Marketing Corporation (Silahis) purchased various merchandise from Gregorio de Leon, doing business as Mark Industrial Sales, under several invoices totaling ₱22,213.75, payable within 30 days.
- Deliveries occurred in October, November, and December 1975.
- Complaint and Counterclaims
- De Leon filed a collection suit in the CFI of Manila for the unpaid invoices, accrued interest of ₱661.03, attorney’s fees of ₱5,000.00, and costs of litigation.
- Silahis admitted the invoices but raised two affirmative defenses:
- A debit memo for ₱22,200.00 as “unrealized profit” or commission allegedly due for a direct sale of sprockets worth ₱111,000.00 to Dole Philippines, Inc., bypassing Silahis.
- A claim to cancel ₱6,000.00 for a defective stainless steel screen returned by its client, Borden International, Davao City.
- Decision of the Court of First Instance
- The lower court confirmed Silahis’s liability on the invoices but allowed a partial offset of ₱22,200.00 for the unrealized commission.
- The court denied the ₱6,000.00 defective-goods counterclaim as time-barred.
- Net judgment: De Leon awarded ₱13.75, plus 12% interest from July 1, 1976; interest and attorney’s fees offset.
- Decision of the Intermediate Appellate Court
- The IAC set aside the lower court’s offset, dismissed Silahis’s counterclaim for commission, and reinstated De Leon’s full claim.
- It found no agreement—verbal or written—obligating De Leon to pay Silahis a commission on the direct sale to Dole Philippines, Inc., and held the debit memo self-serving and unsigned.
Issues:
- Whether Silahis Marketing Corporation is entitled to set off its claim for commission (₱22,200.00) against De Leon’s claim for unpaid invoices.
- Whether the debit memo constitutes a binding contract or liquidated debt for compensation purposes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)