Case Summary (G.R. No. 253825)
Applicable Law
The dispute primarily involves the provisions of the 1987 Philippine Constitution and Republic Act No. 7394, known as The Consumer Act of the Philippines, which regulates consumer protection and establishes the standards for product safety and seller liability.
Background of the Case
In September 2007, the respondents purchased several chocolate bars from the petitioner. Upon opening the bars, they discovered contamination with maggots and cobwebs. They reported this to Cadbury Adams Philippines, which offered compensation of P7,000. The respondents experienced a second similar incident in January 2008. After no adequate investigation by Cadbury, the respondents lodged a complaint with the Department of Health (DOH), which confirmed the chocolate was unfit for consumption but ultimately dismissed the complaint due to lack of jurisdiction over the damage claims.
Initial Actions Taken by the Respondents
Subsequently, the respondents initiated legal proceedings against the petitioner, alleging that it engaged in malicious acts by selling infested products and failing to adequately compensate them. In its defense, the petitioner argued that the complaint was barred by laches and prescription, asserting that the lack of an official receipt for the purchased chocolates nullified the respondents' claims.
Ruling of the Regional Trial Court (RTC)
On December 9, 2016, the RTC ruled in favor of the respondents, stating they had sufficiently proven their case and awarded them P50,000 in temperate damages and P10,000 in actual damages for litigation costs. The RTC found the petitioner liable under the provisions of the Consumer Act due to negligence in selling contaminated chocolate products.
Court of Appeals (CA) Decision
The CA affirmed the RTC’s decision on July 26, 2019, emphasizing that proving the purchase could be established through evidence other than an official receipt, such as the testimony of the respondents. The CA noted the petitioner’s obligation to maintain product safety and suggested negligence in its operations.
Issue on Appeal
The pivotal issue before the Supreme Court is whether the petitioner can be held liable for damages in the absence of receipts. The petitioner contends that both the RTC and CA erred in attributing liability without conclusive evidence of the purchase.
Supreme Court's Analysis
The Supreme Court ruled against the petitioner, asserting that the CA made no reversible errors in upholding the RTC's findings. The review by the Supreme Court highlighted that a failure to present receipts does not negate the respondents’ testimony and other circumstantial evidence supporting their claims. The Court reiterated the principle t
...continue readingCase Syllabus (G.R. No. 253825)
Overview of the Case
- This case involves a petition for review on certiorari filed by Gaisano Superstore, Inc. (Valencia City Branch) against the spouses Frank Rhedey and Jocelyn Rhedey, seeking to overturn the decision and resolution of the Court of Appeals (CA).
- The CA's decision affirmed the Regional Trial Court's (RTC) ruling that ordered the petitioner to pay damages to the respondents due to the sale of contaminated Cadbury chocolate bars.
Background and Antecedents
- Respondents purchased several Cadbury chocolate bars in September 2007, only to discover them infested with maggots, maggot eggs, and cobwebs upon opening.
- After notifying Cadbury Adams Philippines, Inc., the company offered a compensation of P7,000.00.
- On January 29, 2008, a similar incident occurred when respondents purchased eight more chocolate bars, all found to be infested.
- Following a lack of a satisfactory response from Cadbury regarding an investigation, respondents lodged a complaint with the Department of Health (DOH), which confirmed the chocolate's unsuitability for consumption but dismissed the complaint due to lack of jurisdiction for damages amounting to P10,000,000.00.
- After unsuccessful attempts to obtain compensation, respondents filed a civil suit against both Cadbury and Gaisano Superstore for damages.
Proceedings in the Regional Trial Court (RTC)
- The petitioner argued that the complaint was barred by laches and prescription, highlighting the absence of proof of purchase attached to the complaint.
- The RTC, in its ruling on December 9, 2016, found in favor of the respondents, awarding them:
- P50,000.00 as tempera