Case Summary (G.R. No. 70451)
Factual Background
On December 12, 1978, Gaw's enterprise became one of four exclusive dealers for white cement from PWCC. The dealership agreement required Gaw to pay a deposit and stipulated monthly delivery quotas. Subsequently, on February 2, 1979, Gaw entered into a marketing agreement with Uy Diet Tan, allowing Tan to withdraw cement and necessitating a separate deposit of P250,000. However, PWCC refused to accept Tan’s deposit, which led to a series of disputes and legal actions.
Legal Proceedings Leading to the Dispute
Tan filed a complaint against Gaw for specific performance and damages after PWCC refused to accept the deposit intended for Gaw’s account. The initial court ruling granted Tan a restraining order against Gaw, leading to substantial financial claims from both parties. Gaw subsequently sought damages against Tan for losses incurred following the restraining order.
Trial Court Decision
The trial court, after considering the evidence presented, ruled in favor of Gaw, ordering Tan to pay him P20,000 as actual damages and P10,000 as attorney's fees. The court based its decision on the assertion that the restraining order caused Gaw to incur losses from a profitable contract with Mandee Commercial.
Intermediate Appellate Court Reversal
The Intermediate Appellate Court reversed the trial court's decision, asserting that the claims for damages from Gaw should have been included in Tan's initial complaint. The appellate court held that Gaw failed to demonstrate that the restraining order was maliciously sought or lacked probable cause, citing precedents regarding prosecutorial malice.
Supreme Court Review
Gaw petitioned for a review, arguing errors of both law and fact. The Supreme Court acknowledged the usual limitation of its jurisdiction concerning appellate court findings but recognized that conflicts between the trial court and appellate court necessitated a review of factual findings.
Conflicting Factual Findings
The trial court and the appellate court disagreed on whether the marketing agreement was effectively executed. The appellate court contended that Gaw was at fault for not implementing the agreement properly, while the trial court placed responsibility on the restraining order's impact.
Legal Assessment of Contracts
The Supreme Court examined the contractual agreements between Gaw and Tan, emphasizing that the written terms must be clos
...continue readingCase Syllabus (G.R. No. 70451)
Case Overview
- This case involves a petition for review on certiorari filed by Henry H. Gaw against the Intermediate Appellate Court and Uy Diet Tan.
- The decision of the Intermediate Appellate Court reversed the ruling of the Court of First Instance of Rizal, which awarded Gaw damages against Tan.
- The appellate court ordered Gaw to pay Tan damages instead.
Background of the Case
- Henry H. Gaw is engaged in the hardware and construction materials business through his firm, K. H. Gaw Enterprises.
- On December 12, 1978, Gaw entered a dealership agreement with Prime White Cement Corporation (PWCC) to become one of its exclusive dealers for white cement.
- The agreement required Gaw to take a minimum delivery of 2,600 bags of white cement per month and to deposit P200,000.00 with PWCC.
Marketing Agreement
- On February 2, 1979, Gaw entered into a marketing agreement with Uy Diet Tan to facilitate an increase in the monthly allocation of cement.
- The marketing agreement specified that Tan would be entitled to withdraw 50% of Gaw’s allocation and required Tan to deposit P250,000.00 with PWCC.
- The agreement also established payment terms for Tan to Gaw and outlined responsibilities regarding taxes and invoicing.
Issues with Deposit
- On February 8, 1979, Tan attempted to deposit the P250,000.00 check with PWCC, but the deposit was refused. PWCC claimed accepting the deposit in Tan's name would violate Gaw's dealership agreement.
- In response, Tan's counsel wrote to PWCC to confirm his intention to deposit the amount under Gaw's name to comply with the dealership agreement.
Legal Action Initiated by Tan
- Tan filed a complaint against Gaw for specific perfo