Case Summary (G.R. No. L-4440)

Subject-Matter of the Contract

• The contract in question pertains to the sale of Philippine copra, specifically 500 long tons.
• The contract does not specify a particular lot of copra or the location from which it is to be sourced.
• The vendor has the discretion to acquire copra from any part of the Philippines.
• The court determined that the subject-matter of the contract is generic rather than specific.

Loss of Generic Subject-Matter

• A generic obligation remains valid despite the loss of a specific item within that category.
• The principle "genus nunquam perit" applies, meaning that the loss of a generic item does not extinguish the obligation to deliver a substitute of the same kind.
• The distinction between generic and specific obligations is crucial in determining liability.

Appellee's Right to Assign Errors

• An appellee may assign errors in their brief to uphold the judgment on different grounds.
• However, if the appellee seeks to modify or reverse the judgment, they must file an appeal.
• This principle is supported by various precedents in Philippine jurisprudence.

Background of the Case

• Plaintiffs sought damages due to the defendants' failure to deliver the agreed quantity of copra within the stipulated timeframe.
• The contract was executed on October 22, 1947, with specific terms regarding pricing and delivery.
• The plaintiffs claimed damages amounting to P180,000 due to the defendants' non-compliance.

Defendants' Response

• The defendants denied the existence of a valid contract, asserting that the representative who signed lacked authority.
• They claimed that the contract was with a different entity based in Tacloban, not Cebu.
• The defendants also cited force majeure as a defense, claiming that a storm destroyed the copra intended for delivery.

Court's Decision and Appeal

• The trial court ruled in favor of the plaintiffs, awarding them P79,744 in damages.
• The defendants appealed, primarily contesting the court's finding of liability despite their claim of force majeure.
• The appeal focused on the legal interpretation of the contract and the nature of the obligation.

Analysis of the Contract

• The court examined the contract, confirming that it involved a generic obligation to deliver copra.
• The destruction of copra stored in Samar does not extinguish the defendants' obligation to deliver copra from another source.
• The court referenced legal principles distinguishing between determinate and generic obligations.

Damages and Liability

• The plaintiffs claimed they incurred additional damages due to their reliance on the contract with the defendants.
• The trial cou...continue reading