Title
Yu Tek and Co. vs. Gonzalez
Case
G.R. No. 9935
Decision Date
Feb 1, 1915
Yu Tek & Co. sued Basilio Gonzalez for breach of contract after he failed to deliver 600 piculs of sugar. The court ruled parol evidence inadmissible, deemed the contract executory, and awarded liquidated damages of P1,200 plus P3,000.

Case Digest (G.R. No. 9935)
Expanded Legal Reasoning Model

Facts:

  • Contractual Agreement
    • Basilio Gonzalez acknowledged receipt of ₱3,000 from Yu Tek & Co. and obligated himself to deliver 600 piculs of first- and second-grade sugar, as determined by polarization, between January 1 and March 31, 1912.
    • Delivery was to be made at any place within the municipality of Santa Rosa designated by Yu Tek & Co. or its representative.
    • Clause for non-performance: if Gonzalez failed to deliver within the time agreed, the contract would be rescinded and he would return ₱3,000 plus ₱1,200 as indemnity for loss and damages.
  • Performance and Trial Outcome
    • No sugar was delivered, nor was the ₱3,000 returned to the plaintiff.
    • Trial court awarded Yu Tek & Co. ₱3,000 but denied the claim for ₱1,200. Both parties appealed.

Issues:

  • Defendant’s Contentions
    • Whether parol evidence is admissible to show an unexpressed condition that the sugar must come from Gonzalez’s own crop, excusing performance when his crop failed.
    • Whether the contract constituted a perfected sale such that loss of the thing due (crop failure) would relieve the seller under Civil Code Arts. 1450, 1452, 1096, and 1182.
  • Plaintiff’s Contention
    • Whether Yu Tek & Co. is entitled to enforce the ₱1,200 clause as liquidated damages under paragraph 3 of the contract.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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