Title
Pacific Farms, Inc. vs. Esguerra
Case
G.R. No. L-21783
Decision Date
Mar 25, 1970
Pacific Farms, Inc., owner of buildings constructed with unpaid materials from Carried Lumber, must compensate under Article 447, despite good faith.
A

Case Summary (G.R. No. L-21783)

Applicable Law

This case revolves around the Civil Code of the Philippines, especially Article 447, which provides rules regarding obligations related to the sale of goods and the ownership of property.

Motion for Reconsideration

The main issue at hand is the motion for reconsideration filed by Pacific Farms, Inc., disputing a previous decision that held it liable for the unpaid portion of the procurement price of lumber and construction materials supplied by Carried Lumber Company. The plaintiff-appellee contends it should not be liable because it purchased the buildings in good faith.

Assumption of Good Faith

The plaintiff's argument was fundamentally flawed as it misinterpreted the basis of the original ruling. The court clarified that it had held Pacific Farms, Inc. liable not due to a lack of good faith in its purchase but rather based on the principle of accessory obligations under Article 447. The court explicitly stated that it assumed the plaintiff was indeed a good faith purchaser.

Analysis of Ownership and Obligation

The court concluded that despite the absence of direct ownership of the land on which the buildings were constructed, Pacific Farms, Inc. claimed ownership of the buildings made from the appellant's materials. Thus, the court regarded the buildings as the principal, while the lumber and materials served as accessories. Hence, the obligation to pay for these materials rightly rested with the plaintiff, who benefited from their installation in the buildings.

Right of Recovery

Given that the defendant-appellant had no intention or capability to remove the materials without damaging the buildings and that the plaintiff benefited from the accession, the court determined that the obligation to compensate the appellant lay with Pacific Farms, Inc. The original ruling was not that the appellee owed damages but that it was only required to settle the unpaid price for the materials supplie

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