Case Digest (G.R. No. 176949) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In University of the Philippines v. Philab Industries, Inc. (G.R. No. 152411, September 29, 2004), the University of the Philippines (UP) undertook in 1979 to build a Research Complex at UP Los Baños. The Ferdinand E. Marcos Foundation (FEMF) agreed to fund laboratory furniture for the National Institute of Biotechnology and Applied Microbiology (BIOTECH). Through its Executive Assistant Renato Lirio and BIOTECH Deputy Director William Padolina, FEMF directed PHILAB Industries, Inc. to fabricate and deliver furniture, and FEMF remitted three partial payments totalling P2,288,573.74. No formal contract was executed with PHILAB, and despite repeated demands from 1985 to 1986, FEMF failed to pay the final P702,939.40. PHILAB then sued UP for sum of money and damages, alleging that UP promised payment, while UP maintained that it was a mere donee-beneficiary under the 1982 Memorandum of Agreement (MOA) with FEMF, which obligated FEMF alone to pay. The Regional Trial Court dismissed Case Digest (G.R. No. 176949) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Integrated Research Complex Project at UP Los Baños
- In 1979, the University of the Philippines (UP) decided to build a Research Complex; the Ferdinand E. Marcos Foundation (FEMF) agreed to fund laboratory furniture for BIOTECH at UP Los Baños.
- Renato E. Lirio (FEMF) and Dr. William Padolina (BIOTECH) engaged Philab Industries, Inc. (PHILAB) on July 23, 1982 to fabricate and deliver furniture; PHILAB was asked to provide shop drawings and a draft contract.
- Deliveries, Payments, and the MOA
- PHILAB made partial deliveries inspected by BIOTECH and FEMF. FEMF paid PHILAB ₱600,000 (Aug 24, 1982), ₱800,000 (Oct 22, 1982), and ₱836,119.52 (Aug 11, 1983) through Padolina—totaling ₱2,288,573.74 of the ₱2,934,068.90 contract price.
- On October 16, 1982 UP and FEMF executed a Memorandum of Agreement (MOA) obliging FEMF to donate up to ₱29 million for the Research Complex; no written contract was ever finalized between PHILAB and FEMF or UP for the furniture.
- Demands and Litigation
- PHILAB’s final invoice of ₱702,939.40 (July 1, 1984) went unpaid. Between 1985–1986, PHILAB sent multiple demand letters to BIOTECH, UP officials, President Aquino, and PCGG; no payment followed due to the 1986 upheaval.
- PHILAB sued UP for sum of money and damages; the RTC dismissed the complaint (holding FEMF liable), the CA reversed (holding UP liable under unjust enrichment), and UP brought the case to the Supreme Court.
Issues:
- Whether PHILAB entered into a valid contract of sale with FEMF and/or with UP.
- Whether UP can be held liable to PHILAB under the doctrine of unjust enrichment despite not being a contracting party.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)