Case Digest (G.R. No. 123892) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jazmin Soler v. Court of Appeals, Commercial Bank of Manila, and Nida Lopez (G.R. No. 123892, May 21, 2001), petitioner Jazmin Soler, a licensed interior designer and University of Santo Tomas Fine Arts graduate, was invited in November 1986 by Nida Lopez, branch manager of the Commercial Bank of Manila (formerly Boston Bank of the Philippines), to prepare renovation designs for the bank’s Ermita branch. Despite her initial hesitation due to other commitments and a tight December deadline, Soler agreed after Lopez assured her of compensation and acceded to Soler’s professional fee of ₱10,000. Soler obtained the blueprints, hired a draftsman and consultants (Engineer Ortanez for electrical layout, architects Frison Cruz, De Mesa, and Jackie Barcelon for drafting), and secured supplier quotations. By December 1986, Soler submitted the layouts and was praised by Lopez. Subsequent demands for payment were ignored; Lopez later denied any agreement existed and claimed Soler’s desig Case Digest (G.R. No. 123892) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Jazmin Soler is a University of Santo Tomas Fine Arts graduate and licensed interior designer.
- Respondents are The Commercial Bank of Manila (COMBANK, formerly Boston Bank of the Philippines) and its Ermita Branch manager, Nida Lopez.
- In November 1986, at the instance of Rosario Pardo, petitioner met with Lopez, who requested renovation designs and agreed to pay Soler a professional fee of ₱10,000.
- Work Performance and Submission
- The parties discussed renovation of the conference room, carpeting, wallpaper, bookshelves, second-floor clerical area, kitchen, ceiling, and teller booths.
- Soler obtained building blueprints, hired draftsman Jackie Barcelon and architects Cruz and De Mesa, and paid them (Engineer: ₱4,000; Cruz & De Mesa: ₱5,000; Barcelon: ₱6,000). She also solicited quotations from suppliers.
- By December 1986, Soler submitted the completed designs; Lopez expressed approval but later refused payment, claiming the designs did not conform to bank policy.
- Demand and Procedural History
- In early 1987, petitioner’s demands for her fee and return of blueprints were ignored.
- May–June 1987 demand letters went unanswered.
- October 13, 1987: Soler filed a complaint in the RTC of Pasig for collection of professional fees and damages.
- November 19, 1990: RTC rendered judgment awarding Soler ₱15,000 (quantum meruit), ₱5,000 attorney’s fees, ₱2,000 litigation expenses, ₱5,000 exemplary damages, and costs.
- October 26, 1995: The Court of Appeals reversed, holding no contract existed between Soler and COMBANK.
- Soler petitioned the Supreme Court, which granted certiorari.
Issues:
- Existence and Perfection of Contract
- Whether an enforceable, perfected contract existed between Soler and COMBANK through Lopez.
- Whether Lopez had authority to bind COMBANK to the agreement.
- Remedies and Liability
- Whether Soler may recover on a quantum meruit basis for services rendered.
- Whether COMBANK is estopped from denying its officer’s authority to contract.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)