Title
Supreme Court
Soler vs. Court of Appeals
Case
G.R. No. 123892
Decision Date
May 21, 2001
A professional designer, Jazmin Soler, sued COMBANK for unpaid fees after submitting accepted designs. The Supreme Court ruled in her favor, finding a perfected oral contract and apparent authority of the bank manager, entitling Soler to payment under quantum meruit.

Case Digest (G.R. No. 123892)
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)

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