Title
Tanguilig vs. Court of Appeals
Case
G.R. No. 117190
Decision Date
Jan 2, 1997
Contract dispute over windmill construction; deep well excluded, collapse due to defects; petitioner liable for reconstruction under guaranty, respondent to pay balance.

Case Digest (G.R. No. 117190)
Expanded Legal Reasoning Model

Facts:

  • Contract Formation and Payments
    • April 1987: Petitioner Jacinto M. Tanguilig, trading as J.M.T. Engineering and General Merchandising, offered to construct a windmill system for respondent Vicente Herce Jr. for ₱60,000.00, with a one-year guaranty from completion and acceptance.
    • Respondent paid ₱30,000.00 as down payment and ₱15,000.00 as an installment, leaving a remaining balance of ₱15,000.00.
  • Initiation of Lawsuit and Defenses
    • March 14, 1988: Petitioner filed a complaint to collect the ₱15,000.00 balance.
    • Respondent pleaded that he had already paid ₱15,000.00 to San Pedro General Merchandising Inc. (SPGMI) for constructing the deep well to which the windmill was to be connected and sought to offset defects in the windmill system that caused its collapse after a strong wind.
  • Trial Court Findings
    • The trial court found that the construction of the deep well was not part of the windmill contract, based on the content of petitioner’s letter-proposals.
    • It held there was no clear proof that the windmill collapsed due to defective construction and attributed the collapse to force majeure.
  • Court of Appeals Decision
    • The Court of Appeals reversed the trial court, ruling that the deep well installation was included in the agreement (citing mention of “deep well” in proposals and testimony of SPGMI’s proprietor).
    • It applied respondent’s ₱15,000.00 payment to SPGMI against his debt to petitioner and ordered petitioner to reconstruct the windmill under the one-year guaranty, rejecting the force majeure defense.

Issues:

  • Whether the contract to construct a windmill system included the installation of a deep well.
  • Whether petitioner is obliged to reconstruct the windmill after its collapse under the one-year guaranty.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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