Case Digest (G.R. No. 120553)
Facts:
In Toyota Shaw, Inc. v. Court of Appeals and Luna L. Sosa (G.R. No. 116650, May 23, 1995), the private respondent, Mr. Luna L. Sosa, sought to purchase a Toyota Lite Ace in early June 1989. Despite a tight seller’s market, Sosa secured an assurance from Toyota Shaw, Inc.’s sales representative, Popong Bernardo, that a yellow Lite Ace would be ready for pick-up on June 17, 1989. On June 4, 1989, Bernardo signed Exhibit “A,” titled “AGREEMENTS BETWEEN MR. SOSA & POPONG BERNARDO OF TOYOTA SHAW, INC.,” which promised delivery on June 17 and set a downpayment of ₱100,000.00 on June 15. The following day, Sosa and his son Gilbert completed a Vehicle Sales Proposal (VSP) No. 928, reflecting a downpayment of ₱53,148.00, various fees and accessories totaling ₱100,000.00, and a balance of ₱274,137.00 to be financed by B.A. Finance Corporation. On June 17, Toyota delayed delivery until 2:00 p.m. and ultimately refused to release the vehicle, attributing its non‐delivery either to a strongeCase Digest (G.R. No. 120553)
Facts:
- Background of transaction
- Luna L. Sosa sought to purchase a Toyota Lite Ace for use on June 19, 1989; met Popong Bernardo, sales representative of Toyota Shaw, Inc., who signed Exhibit “A” on June 4, 1989 detailing:
- Submission of documents after Sosa’s arrival from Marinduque
- Downpayment of ₱100,000 on June 15, 1989 and delivery on June 17, 1989 at 10 a.m.
- On June 15, 1989, Sosa’s son Gilbert signed Vehicle Sales Proposal (VSP) No. 928; breakdown of initial cash outlay included downpayment, insurance, fees, accessories (total ₱100,000) and a ₱274,137 balance to be financed by B.A. Finance
- Delivery failure and refund
- June 17, 1989: Bernardo first postponed delivery from 10 a.m. to 2 p.m., then refused release—Toyota alleged financing disapproval; Sosa claimed unit was delivered to another buyer
- Same day, Toyota refunded the ₱100,000 via Far East Bank check; Sosa reserved future claims for damages and sent demand letters (June 27 and November 4, 1989)
- Judicial proceedings
- Trial court (RTC Branch 38, Marinduque) held Exhibit “A” a perfected contract, found Toyota in bad faith, awarded moral (₱75,000), exemplary (₱10,000) damages, attorney’s fees (₱30,000) and costs
- Court of Appeals (CA-G.R. CV No. 40043) affirmed in toto; Toyota petitioned the Supreme Court for certiorari
Issues:
- Primary issue
- Whether Exhibit “A,” signed by Toyota’s sales representative, was a perfected contract of sale binding Toyota to deliver the vehicle
- Related issues
- Whether the VSP constituted the true and documented understanding leading to sale
- Whether Sosa had a demandable right to delivery despite unpaid balance and financing non-approval
- Whether Toyota acted in good faith in withholding delivery
- Whether Toyota could be held liable for moral, exemplary damages and attorney’s fees
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)