Title
Philippine Virginia Tobacco Administration vs. Delos Angeles
Case
G.R. No. L-30085-87
Decision Date
Dec 26, 1974
PVTA appealed a partial judgment on unpaid tobacco shipments, but the Supreme Court ruled its appeal moot due to voluntary execution of the judgment, upholding the trial court's decision.

Case Summary (G.R. No. L-45031)

Allegations and Background

The private respondents filed civil complaints against PVTA, alleging that it had failed to pay for tobacco deliveries which were accepted under a procurement contract with FVTR, appointed as their procurement agent. The complaints sought recovery for amounts due for tobacco worth a total of approximately P956,899.42 across the three cases. The respondents argued that despite several deliveries and purported liability under the contract, PVTA failed to honor its financial obligations.

PVTA's Defense

In its defense, PVTA contended that it had only contracted for the procurement of 2 million kilos of Virginia tobacco and articulated that any receipt of additional shipments should not be construed as liabilities under the contract. PVTA's assertion included that it had a right to cross-claim against FVTR for any excess shipments received without proper authorization. FVTR, on its part, claimed it acted solely as an agent for PVTA and, therefore, cannot be held liable for PVTA's failure to pay for the tobacco shipments.

Consolidation and Stipulation of Facts

The three civil cases were consolidated, and on December 13, 1967, the parties entered into a "Stipulation of Facts" that included admissions regarding the parties' legal standing, the procurement contract, the accepted shipments, and the amounts due. This stipulation was presented to facilitate a partial judgment by the court, acknowledging the complexities around the payments and contracts involved.

Partial Judgment

On December 15, 1967, the court rendered a partial judgment ordering PVTA to pay specific amounts to the private respondents, alongside the matter of attorney's fees and interest. The judgment specified amounts owed to each plaintiff, detailing interest computations based on acceptance dates of the shipments, as well as some counterclaims by certain plaintiffs against PVTA.

Appeal and Subsequent Proceedings

PVTA subsequently filed a notice of appeal and a motion for an extension to file the record on appeal. However, the respondents moved to strike out PVTA's appeal, alleging it was frivolous and sought reconsideration against the partial judgment. The court ultimately granted this motion, citing grounds such as the acceptance of benefits under the judgment by PVTA, which led to its appeal being struck from the records.

Legal Basis for Court’s Decision

The court placed emphasis on PVTA's acceptance of the benefits under the partial judgment, concluding that such

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