Case Summary (G.R. No. L-17527)
Conditional Sale Agreement and Claims
The plaintiff sought to recover the sum of P1,404.00, which is the price of the air conditioner, in addition to interest of 12% from January 6, 1959, until full payment, alongside P200 for attorney's fees and costs. The defendant, however, contended that the air-conditioner was destroyed by fire on December 28, 1958, claiming that this event constituted force majeure and relieved him of any liability under the conditional sale agreement. The defendant specifically contended that the fire was not a result of his fault or negligence.
Stipulation of Facts
During the trial, both parties entered a stipulated set of facts, noting the existence of the conditional sale agreement and the timeline of events. The contract price was P1,678.00 with a down payment of P274.00 made by the defendant on December 6, 1958. The air-conditioner was installed by the plaintiff in the defendant's office located at Gardiner Street, Lucena, Quezon. The defendant admitted he did not pay any subsequent installments of P78.00, leaving an unpaid balance of P1,404.00.
Ruling of the Court of First Instance
The Court of First Instance ruled in favor of the plaintiff, ordering the defendant to pay the claimed amount plus interest and attorney's fees. The court held that the buyer assumed the risk of loss under the terms of the conditional sale agreement, which specified the buyer's obligation to keep the property in good condition and acknowledged that loss from any cause would be at the buyer's risk.
Appeal and Legal Arguments
The defendant appealed directly to the Supreme Court on a question of law, arguing that since title to the property would only pass upon full payment, the loss of the air conditioner should be the vendor’s loss. He interpreted the phrase "for any cause" as not inclusive of fortuitous events that are entirely beyond his control. The defendant also cited Article 1174 of the new Civil Code which recognizes exceptions to liability for fortuitous events, arguing that the language of the contract lacked intent to impose such responsibility on him for losses from these events.
Response and Court's Reasoning
The plaintiff countered that the contract stipulation making the buyer liable for losses irrespective of the cause does not contravene public policy and is permissible under Article 1174 of the Civil Code. They maintained that the risk of loss was expressly taken on by the buyer, a conditio
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Case Background
- This case involves an action initiated by Sun Brothers Appliances, Inc. (plaintiff and appellee) against Damaso P. Perez (defendant and appellant) to recover the sum of P1,404.00.
- The claim arises from a Conditional Sale Agreement executed on December 6, 1958, concerning an Admiral Air Conditioner, Slim Style, Model 100-23-1 H.P., Serial No. 2978828.
- The plaintiff seeks the amount due, plus 12% interest from January 6, 1959, attorney's fees of P200, and costs associated with the lawsuit.
Defendant's Position
- The defendant acknowledges receipt of the air conditioner but asserts that it was destroyed by fire on December 28, 1958, which he claims was a result of force majeure.
- He contends that since the destruction was not due to his fault or negligence, he should not be held liable for the remaining balance under the Conditional Sale Agreement.
Stipulation of Facts
- The parties entered into a stipulation of facts during the trial which included the following key points:
- The defendant admitted to entering into the Conditional Sale Agreement on December 6, 1958.
- The air conditioner was installed at the defendant's office in Lucena, Quezon, on December 14, 1958.
- A down payment of P274.00 was made by the defendant, with a remaining balance of P1,404.00.
- The air conditioner was destroyed in a fire on December 27, 1958.
- The parties agreed to leave the resolution