Case Summary (G.R. No. 154106)
Summary of Facts
WENCESLAO entered into a contract with the Public Estates Authority (PEA) for infrastructure work and subsequently contracted READYCON for asphalt materials valued at P1,178,308.75 on April 16, 1991. WENCESLAO was required to pay a 20% downpayment upon delivery, with the remaining amount due within 15 days. READYCON delivered the asphalt materials on April 22, 1991, and received the downpayment. However, WENCESLAO failed to remit the balance after READYCON performed its obligations, leading to a demand for payment that went unheeded.
Complaint and Initial Proceedings
As a result of non-payment, READYCON filed a complaint with the Regional Trial Court (RTC) of Pasig City on July 19, 1991, seeking collection of P1,014,110.45, which included unpaid amounts and sought a writ of preliminary attachment against WENCESLAO. Following this, the necessary bond was posted, allowing for the attachment of WENCESLAO's heavy equipment.
Court Decisions
The RTC ruled in favor of READYCON on December 26, 1994, ordering WENCESLAO to pay the claimed sum with interest and attorney’s fees, while dismissing WENCESLAO's counterclaim for lack of merit. WENCESLAO appealed to the Court of Appeals, which affirmed the RTC's decision in full. The appellate court noted that malice or bad faith was not substantiated by WENCESLAO in relation to the issuance of the writ of preliminary attachment.
Issues on Appeal
In the subsequent petition, WENCESLAO raised several issues: whether the appeal involved factual questions, respondents’ liability for damages from wrongful attachment, and whether the obligation was demandable. The court found that it would specifically address if READYCON should be held liable for damages from the writ and if WENCESLAO's payment was due.
Determination of Liabilities and Obligations
On the first issue regarding damages due to the attachment, WENCESLAO claimed economic losses amounting to P1.9 million stemming from operational paralysis due to the writ. However, READYCON argued against the existence of bad faith in obtaining the writ. The court clarified that while attachment may cause damages, liability for such damages requires concrete evidence of wrongful conduct. The courts found that READYCON had properly sought the writ based on lawful grounds, thus negating claims for damages related to wrongful attachment.
Clarity of Payment Terms
Regarding the demand for payment, WENCESLAO contended that the contract was unclear about when the 15-day period started and that payment should hinge upon government approval of work quality. The court upheld that the explicit te
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Case Overview
- This case involves a petition for review of a decision made by the Court of Appeals, which affirmed the ruling of the Regional Trial Court of Pasig City.
- The main issue centers around the obligation of D.M. Wenceslao and Associates, Inc. (WENCESLAO) to pay Readycon Trading and Construction Corp. (READYCON) for asphalt materials and damages related to the issuance of a writ of preliminary attachment.
Parties Involved
Petitioners:
- D.M. Wenceslao and Associates, Inc.: A domestic corporation engaged in construction, specifically in infrastructure and subdivision development.
- Dominador S. Dayrit: Vice-President of WENCESLAO and signatory of the contract with READYCON.
Respondent:
- Readycon Trading and Construction Corp.: A corporation focused on manufacturing and selling asphalt materials.
Factual Background
- WENCESLAO entered into a contract with READYCON on April 16, 1991, for the sale of asphalt materials valued at P1,178,308.75.
- WENCESLAO was obligated to provide a 20% downpayment upon delivery and settle the remaining balance within 15 days.
- READYCON delivered asphalt materials worth P1,150,531.75 on April 22, 1991, and WENCESLAO paid the downpayment.
- After READYCON's performance, WENCESLAO did not pay the remaining balance despite repeated demands.
Procedural History
- On July 19, 1991, REA