Case Summary (G.R. No. 173320)
Professional Services Contract Summary
On February 16, 1998, Eduardo B. Manzano, the petitioner, and Antonio B. Lazaro, the respondent, entered into a Professional Services Contract that outlined Lazaro's responsibilities as the head of Manzano's campaign for the Vice-Mayoralty post in Makati City. The contract specified roles and responsibilities, remuneration of PHP 70,000 per month, and a bonus of PHP 200,000 if Manzano won the election.
Performance and Payment Issues
Post-election, Manzano won the Vice-Mayoral seat but subsequently informed Lazaro that he would only be paid PHP 15,000 of the agreed remuneration, deferring the balance of PHP 20,000 pending an inventory of campaign materials. Lazaro met this condition, delivering the required equipment, and subsequently demanded full payment, including the promised bonus.
Response from Manzano and Allegations of Breach
Manzano acknowledged the delivery but contended he needed a liquidation of campaign expenses, suggesting that Lazaro failed to fulfill his contractual obligations by being frequently absent during the campaign. In response, Lazaro asserted he was not responsible for managing campaign finances, which was assigned to others. This led to a legal dispute, with Lazaro filing for collection in the Regional Trial Court (RTC).
RTC Decision and Findings
The RTC ruled in favor of Lazaro, ordering Manzano to pay the total amount due, including legal interests and attorney's fees. The court found that any claims of Lazaro's breach were unsubstantiated and highlighted that Manzano's previous acknowledgment of the balance due contradicted his current position, indicating he was using the alleged breach as an excuse to avoid payment.
Appeal to the Court of Appeals
Manzano appealed the RTC's decision, arguing primarily that the appellate court did not consider the alleged breaches by Lazaro in its ruling. He insisted that Lazaro's failure to fulfill his duties justified a denial of the bonus and the remaining professional fees owed.
Court of Appeals’ Ruling
The Court of Appeals affirmed the RTC's ruling, emphasizing that the fundamental issue was whether the obligations under the contract were fulfilled, which they found Lazaro had accomplished. The appellate court also stressed that any alleged vitiation of consent did not render the contract unenforceable since it was still a valid agreement until annulled through proper legal channels.
Supreme Court’s Conclusion
The Supreme Court upheld the decisions of the RTC and the Court of Appeals, reiterating that contractual obligations must be honored unless legally set aside. The findings of the lower courts were supported by substantial evidence, and Manzano's claims were deemed insufficient to counter the presumption of validity in the contract's execut
...continue readingCase Syllabus (G.R. No. 173320)
Case Overview
- This case concerns a Petition for Review on Certiorari filed by Eduardo B. Manzano (Petitioner) against Antonio B. Lazaro (Respondent).
- The dispute arises from a Professional Services Contract dated February 16, 1998, which pertained to Lazaro's services during Manzano's candidacy for the Vice-Mayoralty post in Makati City.
- The Court of Appeals affirmed the decision of the Regional Trial Court (RTC), which ruled in favor of Lazaro.
Facts of the Case
- Manzano and Lazaro entered into a contract that defined their roles, responsibilities, remuneration, and conditions for payment.
- The contract stipulated that Lazaro would be compensated PHP 70,000 per month and an additional bonus of PHP 200,000 upon Manzano's electoral victory.
- Manzano won the Vice-Mayoralty election, but Lazaro later discovered that he would only be paid PHP 15,000, with a PHP 20,000 balance contingent upon a final inventory of campaign materials.
- Disputes arose when Lazaro demanded payment of his full compensation and bonus, claiming he had fulfilled his responsibilities, while Manzano alleged Lazaro had not met his obligations during the campaign.
Legal Issues Presented
- The primary legal issues involved whether the Professional Services Contract was voidable, the material breach of contract by Lazaro, and whether he was entitled to the bonus pay despite the alleged breach.
- Manzano contended that Lazaro's failure to perform his duties constituted a breach of contract and that Lazaro misrepresented his qualifications.
RTC Decision
- The RTC ruled in favor of