Title
Victorias Milling Co. vs. Court of Appeals
Case
G.R. No. 117356
Decision Date
Jun 19, 2000
VMC refused CSC's sugar withdrawal after STM assigned rights under SLDR No. 1214M. Court ruled CSC as assignee, not agent, entitled to 23,000 bags; VMC's claims of fraud, compensation, and conditional sale rejected.

Case Summary (G.R. No. 117356)

Relevant Dates and Documentary Instruments

Key documents and dates: SLDR No. 1214M dated October 16, 1989 covering 25,000 bags of sugar (50 kg per bag) at P638.00 per bag; STM sold its rights in that SLDR to CSC on October 25, 1989 for P14,750,000.00; STM issued postdated checks to VMC on October 27, 1989 and VMC issued Official Receipt No. 33743 acknowledging receipt of checks for 50,000 bags (SLDRs 1213 and 1214); CSC withdrew 2,000 bags and was thereafter refused further withdrawals by VMC.

Factual Background

VMC regularly sold sugar to STM and issued Shipping List/Delivery Receipts (SLDRs) as proof of purchase. STM purchased under SLDR No. 1214M (25,000 bags). STM sold/endorsed its rights under that SLDR to CSC, which tendered payment by checks and sent VMC a letter of authority and a copy of the SLDR. CSC withdrew 2,000 bags from VMC’s NAWACO warehouse, but VMC refused further delivery claiming that STM had already withdrawn all the sugar corresponding to the value of cleared checks. CSC then demanded delivery of the remaining 23,000 bags and ultimately sued for specific performance.

Trial Court Findings and Judgment

The trial court found for CSC. It credited testimony and documentary exhibits (postdated checks, Official Receipt, and VMC’s computer printout marked Exhibit F) showing STM had paid for the sugar under SLDR No. 1214M and that CSC had been denied delivery despite payment. The trial court ordered VMC to deliver 23,000 bags, awarded unrealized profits and exemplary damages and attorney’s fees.

Court of Appeals Proceedings and Rulings

The Court of Appeals initially modified the trial court judgment to require delivery of 12,586 bags and awarded attorney’s fees equivalent to 10% of the undelivered value; after reconsideration it further modified its decision to order delivery of 23,000 bags and costs of suit. The appellate court explained that Exhibit F could not be used for the narrower purpose of proving a precise number of undelivered bags because evidence must be used only for the purpose for which it was offered; nonetheless, testimonial and other documentary evidence supported CSC’s assertion that only 2,000 bags had been withdrawn and the remaining 23,000 were still due.

Issues Presented to the Supreme Court

Petitioner raised several grounds for review: (1) CSC was STM’s agent, and therefore conclusively presumed to be such and estopped from suing as assignee; (2) the Court of Appeals ignored facts that would reduce VMC’s liability to 69 bags by allowing setoff/compensation for STM’s other unpaid purchases; (3) application of compensation (setoff) rules under Arts. 1279, 1285 and 1626 should have allowed VMC to offset credits from other SLDRs; (4) Exhibit F and account settlement evidence constituted an account stated binding on CSC; (5) SLDR No. 1214M was conditional (subject to availability at NAWACO) so title did not pass and VMC was excused; and (6) the clean hands doctrine should bar CSC due to alleged conspiracy/fraud with STM.

Procedural Threshold: Raising New Issues on Appeal

The Supreme Court observed that some issues (notably agency) were first raised on appeal. While issues not raised at trial are generally not allowed on appeal for fairness and due process reasons, the Court of Appeals nevertheless addressed the agency issue and the Supreme Court proceeded to review it on the merits.

Agency Analysis and Holding

The Court applied the Civil Code definition of agency (Art. 1868) and the established elements: manifestation of the principal’s intent to appoint, the agent’s acceptance, and the principal’s control over the agent’s actions. The Supreme Court held CSC was not STM’s agent. The decisive factor was the parties’ intention: STM’s letter and CSC’s communications characterizing the transaction as a sale and endorsement demonstrated that STM intended to sell and transfer rights under the SLDR to CSC, not to appoint CSC as its agent subject to STM’s control. The mere phrase “for and in our behalf” in STM’s letter did not, in context, establish the control element or the requisite agency relationship. Accordingly CSC could sue in its own name as assignee.

Compensation (Setoff) Analysis and Holding

Petitioner argued for compensation under Article 1279 (setoff) based on other SLDR transactions between STM and VMC. The Court examined whether the obligation for SLDR No. 1214M and VMC’s claim for STM’s unpaid purchases were mutual principal obligations between the same parties such that compensation would apply. The Court accepted the trial and appellate findings that the purchase covered by SLDR No. 1214M was a separate, independent transaction, supported by uncontested evidence that VMC had been paid for that SLDR’s sugar. Because the parties were not mutual principal creditors and debtors with respect to that specific transaction, and the debt under SLDR No. 1214M was not subject to a valid setoff claim, the Court correctly refused to apply Art. 1279 to extinguish or materially reduce VMC’s liability to CSC.

Conditional Sale / Contract to Sell Analysis and Holding

VMC contended SLDR No. 1214M created only a conditional sale or contract to sell because the SLDR contained a notation about availability at the NAWACO warehouse. The Court examined the SLDR’s express terms and conditions which stated that by payment and receipt of the document, “title to refined sugar is transferred to buyer/trader and delivery to him/it is deemed effected and completed” and that the buyer assumes responsibility. Those stipulations manifested an intention to transfer title upon payment, thereby establishing a sale, not a mere contract to sell. Having prescribed terms that effect transfer of title, VMC was estopped from asserting the sale was conditional in a manner that would excuse non-delivery.

Alleged Conspiracy and Clean Hands Doctrine

VMC asserted a conspiracy between STM and CSC to defraud VMC, arguing that the clean hands doctrine should bar CSC’s relief. Th

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