Case Digest (G.R. No. 264746) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves Marcelina Villanueva, doing business under the name and style "Vedge Trading," as Petitioner, versus Coca-Cola Bottlers Philippines, Inc. (Coca-Cola) and several third-party respondents including Jonathan Erasga, Benjamin I. Dequina, Jr., Allan D. Evangelista, and Eugenio D. Evangelista. The dispute centers on Coca-Cola's complaint filed on November 26, 2012, before the Regional Trial Court (RTC) of Makati City (Civil Case No. 12-1152) seeking collection of a sum of PHP 649,316.00 plus interests for unpaid Coca-Cola products delivered to Vedge Trading. Coca-Cola alleged a dealership agreement with Marcelina, who was registered as the owner of Vedge Trading, granting her the exclusive area to sell Coca-Cola products on credit with payment terms of seven days from the billing date. Marcelina denied knowledge of any dealership agreement, asserting her nephews, the third-party respondents, managed the business and were responsible for the debt. She filed a Third P Case Digest (G.R. No. 264746) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Marcelina Villanueva, doing business under the name "Vedge Trading," is sued by respondent Coca-Cola Bottlers Philippines, Inc. (Coca-Cola) for collection of unpaid products.
- Coca-Cola is engaged in the production, manufacture, distribution, and sale of soft drinks.
- Third party defendants are Marcelina's nephews Jonathan Erasga, Benjamin I. Dequina, Jr., Allan D. Evangelista, and Eugenio D. Evangelista.
- Dealership Agreement and Business Operations
- Coca-Cola and Vedge Trading entered into a dealership agreement granting Vedge Trading exclusive distribution rights and a credit line.
- Coca-Cola delivered products to Vedge Trading subject to payment terms of seven days from billing.
- Delivery invoices and statements of account showed unpaid debt amounting to PHP 649,316.00 from May 23, 2010, to June 21, 2010.
- Litigation History
- Coca-Cola filed a Complaint for collection of money from Marcelina on November 26, 2012.
- Marcelina denied knowledge of such dealership agreement; admitted registering "V.E.D.G.E. Trading" with DTI but claimed her nephews managed business operations.
- Marcelina filed a Third Party Complaint against nephews claiming they should be liable.
- Testimonies and Evidence
- Marcelina testified she financed the business but did not participate in operations; nephews managed the business.
- Dequina and Erasga were Coca-Cola sales representatives, barred from dealership, hence Marcelina registered the business under her name.
- Marcelina visited the warehouse regularly; nephews testified Marcelina was involved in operations and finance discussions.
- Delivery invoices were presented bearing signatures acknowledging receipt.
- Lower Court Decisions
- RTC dismissed the Complaint and Third Party Complaint for lack of cause of action.
- RTC doubted the existence of dealership due to no written agreement presented but considered invoices sufficient proof of delivery.
- RTC found Vedge Trading was a partnership between Marcelina and Erasga; personal assets liable only after partnership assets exhausted, but partnership was not impleaded.
- CA reversed RTC decision, holding Marcelina liable based on delivery invoices and her admissions and visitation. CA ordered payment of principal and interest.
- Petition to the Supreme Court
- Marcelina filed Petition for Review on Certiorari challenging CA ruling.
- Issues concern liability of Marcelina and third party defendants to Coca-Cola.
Issues:
- Whether Marcelina is liable to Coca-Cola for unpaid products totaling PHP 649,316.00 plus corresponding interests.
- Whether the third party defendants (Marcelina's nephews) are liable for Coca-Cola's unpaid products.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)