Title
Sun Brothers Appliances, Inc. vs. Perez
Case
G.R. No. L-17527
Decision Date
Apr 30, 1963
In the case of Sun Brothers Appliances, Inc. v. Perez, the Supreme Court ruled in favor of the plaintiff, holding the defendant liable for the payment of an air-conditioner that was destroyed in a fire, based on a conditional sale agreement that made the buyer responsible for any loss or damage.
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Case Digest (G.R. No. L-17527)

Facts:

  • The case involves Sun Brothers Appliances, Inc. v. Damaso P. Perez.
  • A conditional sale agreement was executed on December 6, 1958, in Manila.
  • Sun Brothers sold an Admiral Air Conditioner, Model 100-23-1 HP, for ₱1,678.00.
  • The defendant, Damaso P. Perez, made a down payment of ₱274.00 on the same day.
  • The air conditioner was installed at the defendant's office in Lucena, Quezon on December 14, 1958.
  • The air conditioner was destroyed by fire on December 28, 1958.
  • The defendant claimed the destruction was due to force majeure and argued against paying the remaining balance of ₱1,404.00.
  • The lower court ruled in favor of the plaintiff, ordering the defendant to pay the outstanding balance, interest, and attorney's fees.
  • The case was appealed to the Supreme Court to address the buyer's liability in cases of loss due to fortuitous events.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the plaintiff, affirming the lower court's decision.
  • The court concluded that the defendant is liable for the payment of the air conditioner, despite its destruction by fire.
  • The stipulation in the conditional sale agreement hold...(Unlock)

Ratio:

  • The court's rationale was based on legal principles governing conditional sales.
  • The agreement specified that title remained with the vendor until full payment, while the risk of loss was transferred to the buyer.
  • Citing Article 1174 of the Civil Code, the court affirmed that parties can stipulate the assignment of risk.
  • The phrase "for any cause" was interpreted to include fortuitous events, validating the buyer's liability for loss due to fire....continue reading

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