Case Summary (G.R. No. 173881)
Facts of the Case
On October 1, 1994, Hyatt and Cathedral Heights executed a Service Agreement, stipulating that Hyatt would maintain the elevators, which included monthly inspections and necessary repairs. From April 1997 to July 1998, Hyatt incurred expenses totaling Php 1,161,933.47 for repairs and maintenance of the elevators, which it sought to recover through demand letters and ultimately through a civil complaint for a sum of money in the Regional Trial Court (RTC).
Trial Court Ruling
The RTC ruled in favor of Hyatt, establishing that a contract of sale existed based on the sales invoices presented and that Cathedral Heights was obligated to pay for services rendered. The court dismissed Cathedral Heights' claims about non-delivery of parts, treating them as an afterthought. An appeal was made by Cathedral Heights based on this ruling.
Court of Appeals Decision
On April 20, 2006, the Court of Appeals (CA) reversed the RTC’s ruling. The CA determined that Cathedral Heights did not consent to the purchases made by Hyatt, which it found crucial for the perfection of the contract of sale. The CA elucidated that there was a lack of a meeting of minds regarding the price and that Hyatt could not dictate prices unilaterally without Cathedral Heights’ consent.
Procedural Issue Raised
In the higher court proceedings, a jurisdictional issue was raised, contending that Hyatt's appeal presented questions of fact rather than law. The Supreme Court acknowledged precedents confirming its limited jurisdiction in reviewing factual determinations. However, it also noted exceptions to this rule, determining that the current case fell under one of those exceptions due to conflicting findings between the RTC and the CA regarding the existence of a perfected contract of sale.
Nature of the Contract and Performance
The essence of the disputes was centered on whether a perfected contract of sale existed concerning the repair parts installed in the elevators. The Service Agreement indicated that Cathedral Heights would pay for additional charges for repair services, but there was disagreement over whether the proper authorization procedures, as outlined in a purported Standard Operating Procedure (SOP), were followed. Cathedral Heights maintained that no purchase orders were issued prior to the repairs, leaving them unable to verify the repairs made.
Evidence and Testimony
Hyatt presented testimony from its finance manager, who described a process where repairs were conducted quickly, prioritizing the operational status of the hospital elevators. The absence of written consent or purchase orders from Cathedral Heights was a critical point of contention. Furthermore, there was a claim that a verbal agreement allowed Hyatt to proceed with repairs without following the SOP's formal steps.
Conclusion of the Supreme Co
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Case Overview
- Court: Supreme Court of the Philippines
- Division: Second Division
- Case Number: G.R. No. 173881
- Date of Decision: December 01, 2010
- Petitioner: Hyatt Elevators and Escalators Corporation
- Respondent: Cathedral Heights Building Complex Association, Inc.
- Nature of Petition: Petition for review on certiorari under Rule 45 of the Rules of Court.
Facts of the Case
- On October 1, 1994, a Service Agreement was signed between Hyatt Elevators and Cathedral Heights Building Complex for the maintenance of four passenger elevators.
- The Service Agreement stipulated that Hyatt was responsible for regular inspections and repairs, while Cathedral Heights would cover additional charges for parts and repairs.
- Between April 1997 and July 1998, Hyatt incurred expenses amounting to Php 1,161,933.47 for elevator maintenance.
- Hyatt sent multiple demand letters for payment, the last dated July 18, 2000, but Cathedral Heights refused to pay.
- Consequently, Hyatt filed a complaint for a sum of money in the Regional Trial Court (RTC) in Quezon City (Civil Case No. Q-01-43055).
RTC Decision
- On March 5, 2003, the RTC ruled in favor of Hyatt, ordering Cathedral Heights to pay the claimed amount plus attorney's fees and costs.
- The RTC based its decision on evidence that indicated a contract of sale for the elevator parts and ruled that Cathedr