The Consolidated Bank and Trust Company v C.A, G.R. No. 138569, September 11, 2003 CASE DIGEST

Facts:

    The private respondent opened a savings account with the petitioner.  The private respondent, through its cashier, Macaraya, filled up a savings deposit slip and saving check deposit slip. Macaraya instructed their messenger, Calapre, to deposit the money with the petitioner. Macaraya also gave Calapre the passbook. Calapre deposited the amount to the petitioner since the transaction took time and he had to make another deposit with a different bank, he left the passbook with the petitioner. When Calapre returned to retrieve the passbook, Teller No. 6 informed him that "somebody got the passbook". Calapre reported it to Macaraya. Macaraya then deposited another amount with the petitioner, when she asked for the passbook, Teller No. 6 told her that someone got the passbook but she could not remember to whom she gave the passbook. The private respondent then called up the petitioner to stop any transactions using the same lost passbook until they could open a new account. On the same day, the private respondent learned that an unauthorized withdrawal was made from its savings account. The withdrawal slip bore the signatures of the authorized signatories of the private respondent. The signatories denied signing the withdrawal slip. A certain Noel Tamayo received the amount from the unauthorized withdrawal.

Issue:

    WoN the petitioner is negligent and liable for damages?

Ruling:

 (Artilcle 1172; 1173)

    Yes, the petitioner is negligent and liable for damages.

    The petitioner breached its contractual obligation to return the passbook only to the authorized representative of the private respondent.

    For breach of the savings deposit agreement due to negligence, or culpa contractual, the bank is liable to the depositor. (Art. 1172)

    The petitioner is bound by the negligence of its employee under the principle of respondent superior or command responsibility. The defense of exercising the required diligence in the selection and supervision of employees is not a complete defense in culpa contractual, unlike in culpa aquiliana.

Note:

    The contract between the bank and its depositor is governed by the provisions of the Civil Code on a simple loan. (Art. 1980)

    In culpa contractual, once the plaintiff proves a breach of contract, there is a presumption that the defendant was at fault or negligent. The burden is on the defendant to prove that he was not at fault or negligent. In contrast, in culpa aquiliana the plaintiff has the burden of proving that the defendant was negligent.

Doctrine of last clear chance

    - where both parties are negligent but the negligent act of one is appreciably later than that of the other, or where it is impossible to do so, is chargeable with the loss; also called contributory negligence; applicable to culpa aquiliana

San Pedro Bus Lines v Navarro, G.R. No. L-6291, April 29, 1954 CASE DIGEST

Facts:

    Navarro is a passenger of one of the buses owned and operated by the petitioner. While on its way to its destination, the bus collided with another vehicle, causing serious physical injuries with subsequent post-traumatic psychosis which might incapacitate the respondent for life. In their answer, the petitioner admitted the occurrence of the accident and the injuries received by the respondent but disclaimed responsibility for the accident. The petitioner also contends that they cannot be held civilly liable for the reason that the Court of First Instance had dismissed the criminal charges against the driver of the bus involved in the accident.

Issue:

    WoN the petitioner is liable for damages?

Ruling:

(Article 1172, 1173)

    Yes, the petitioner is liable for damages.

    The action was not based on tort or quasi-delict but was one for breach of a carrier's contract, there being a clear distinction between culpa as a source and creator of obligations (aquiliana) and culpa in the performance of an already existing obligation (contractual).

Del Prado v Manila Electric, Co., G.R. No. L-29462, March 7, 1929 CASE DIGEST

Facts:

    The respondent is engaged in operating streetcars for the conveyance of passengers. Teodoro Florenciano, a motorman, after the car had stopped at its appointed place for taking on and letting passengers off, it resumed its course at a moderate speed. The car had only proceeded a short distance when the petitioner ran across the street to catch the car, upon approaching the car he raised his hand as an indication to the motorman to his desire to board the car, in response the motorman ease up a little without stopping. The petitioner seized with his hand the front perpendicular handspot at the same time placing his left foot upon the platform, however, before he had secured himself, the motorman applied the power with the result that the car lurches forward slightly. This sudden impulse caused the petitioner to slip and fell to the ground having his right foot caught and crushed by the moving car which eventually was amputated.

Issue:

    WoN the respondent is negligent and liable for damages?

Ruling:

(Article 1172; 1173)

    Yes, the respondent is negligent and liable for damages.

    The relation between a carrier of passengers for hire and its patrons is of a contractual nature; and in failure on the part of the carrier to use due care in carrying its passengers safely is a breach of duty. This duty extends to patrons boarding as well as those alighting therefrom. (culpa contractual)

Note:

culpa aquiliana  

    - liability arising from a tort; not involving a breach of a positive obligation; an employer may exculpate himself by providing that he exercised due diligence to prevent the damage; the court can mitigate liability according to the circumstances of the case

Manuel De Guia v The Manila Electric Railroad and Light Company, G.R. No. L-14335 CASE DIGEST

Facts:

    The petitioner, a physician, boarded a car at the end of the line with the intention of coming to the city. At about thirty meters from the starting point, the car entered a switch, the petitioner remaining on the back of the platform holding the handle of the right-hand door. Upon coming out of the switch, the small wheels of the rear car left the track, ran for a short distance, and struck a concrete post. As the car stopped, the petitioner was thrown against the door, receiving bruises and possible internal injuries. The trial court found that the motorman was negligent for having maintained too rapid a speed. On the other hand, the respondent insisted that the derailment of the car is supposed to be due to a fortuitous event and not the negligence of the motorman, i.e. a stone lodged between the rails at the juncture of the switch, unobserved by the motorman.

Issue:

    WoN the respondent is liable for damages?

Ruling:

(Article 1172)

    Yes, the respondent is liable for damages.

    The petitioner had boarded the car as a passenger for the city of Manila and the company undertook to convey him for hire. The relation between the parties was, therefore, of a contractual nature, and the duty of the carrier is to be determined with reference to the principles of contract law, i.e. the company was bound to convey and deliver the petitioner safely and securely with reference to the degree of care, which, under the circumstances, is required by law and custom applicable to the case. (culpa contractual)

Note:

culpa aquiliana

    - relevant to prove that the company exercise due care in the selection and instruction of the motorman; liability incurred by  negligence in the absence of a contractual relation

Gutierrez v Gutierrez, G.R. No. 34840, Septembet 23, 1931 CASE DIGEST

Facts:

    The case is one of two drivers approaching a narrow bridge from opposite directions, with neither being willing to slow down and give the right of way to the other, with the inevitable result of a collision and an accident.

    A passenger truck and a private automobile collided while attempting to pass each other on a bridge. The truck was driven by Abelardo Velasco and owned by Saturnino Cortez. The private automobile was operated by Bonifacio Gutierrez, a lad, 18 years of age, owned by his parents, Mr. and Mrs. Manuel Gutierrez. At the time of the collision, the father was not in the vehicle, the mother along with the other members of the family. seven in total were accommodated. A passenger of the truck, petitioner herein, was en route to Manila. The collision resulted in the petitioner suffering a fractured right leg. It is conceded that the collision was caused by negligence. The difference is, the petitioner blames both parties; the owner of the passenger truck blames the private automobile; and the private automobile blames the passenger truck.

Issue:

    WoN the private automobile and passenger truck are liable for damages?

Ruling:

(Article 1172)

    Yes, both are liable.

    Civil liability arising from fault or negligence.

    (Private vehicle)

    The running of the machine by a child to carry other members of the family is within the scope of the owner's business so that he is liable for the negligence of the child because of the relationship of master and servant.

    (Passenger truck)

    Liability rests on that of a contract.

Spouses Guanio v Makati Shangrila, G.R. No. 190601, Feb. 7, 2011 CASE DIGEST

Facts:

    For their wedding, the petitioner spouses booked at the Shangri-la Hotel Makati. Prior to the event, the parties agreed on a final price on the food to be served during the wedding reception. A day before the event, the parties finalized and forged their contract. The petitioners claim that the respondent failed to honor their agreement as stated in the contract. Petitioners thus sent a letter-complaint to the Makati Shangri-la Hotel and Resort, Inc. (respondent) and received an apologetic reply from the hotel’s Executive Assistant Manager. They nevertheless filed a complaint for breach of contract and damages. In its answer, the respondent claimed that the petitioner failed to inform the former of the change in the expected number of guest which led to the poor service.

Issue:

    WoN respondent failed to honor their contract?

Ruling:

(Article 1170; 1171; 1338; 1344)

    No, the respondents did not fail to honor their contract.

    Breach of contract is defined as the failure without a legal reason to comply with the terms of a contract. It is also defined as the failure, without legal excuse, to perform any promise which forms the whole or part of the contract.

    The appellate court, and even the trial court, observed that petitioners were remiss in their obligation to inform the respondent of the change in the expected number of guests. The observation is reflected in the records of the case. Petitioners’ failure to discharge such obligation thus excused, as the parties’ contract provides, the respondent from liability for "any damage or inconvenience" occasioned thereby. As for petitioners’ claim that respondent departed from its verbal agreement with petitioners, the same fails, given that the written contract which the parties entered into the day before the event, being the law between them.

    In the present petition, under considerations of equity, the Court deems it just to award by way of nominal damages to petitioners, for the discomfiture that they were subjected to during to the event. 

(Alternative)

Issue:

    WoN the doctrine of proximate cause is applicable to the case?

Ruling:

    No, the doctrine of proximate cause is no applicable.

    The doctrine of proximate cause is applicable only in actions for quasi-delicts, not in actions involving breach of contract. The doctrine is a device for imputing liability to a person where there is no relation between him and another party. In such a case, the obligation is created by law itself. But, where there is a pre-existing contractual relation between the parties, it is the parties themselves who create the obligation, and the function of the law is merely to regulate the relation thus created.

Legaspi Oil v CA, G.R. No. 96505, July 1, 1993 CASE DIGEST

Facts:

    The case involves the sale of copra by Oseraos to the petitioner. A signed contract on behalf of Oseraos was entered into by both parties whereby Oseraos shall deliver to the petitioner the said copras. Oseraos failed to deliver the whole volume of copra he was obliged to deliver. The petitioner demanded the delivery of said copras but Oseraos refused because the prices of copra had gone up from the time they had entered into the contract.

Issue:

    WoN Oseraos' failure to deliver the copra is the fraud referred to by Article 1170?

Ruling:

(Article 1170; 1171; 1338; 1344)

    Yes, Oseraos' failure to deliver the copra is the fraud referred to by Article 1170.

    The fraud referred to in Article 1170 is the deliberate and intentional evasion of the normal fulfillment of the obligation. The conduct of Oseraos clearly manifests his deliberate intent to evade his contractual obligation for the price of copra had gone up.

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Juan Syquia v CA, G.R. No. 98695, Jan. 27, 1993 CASE DIGEST

 Facts:

     The petitioner filed a complaint against Manila Memorial Park Cemetery, Inc. for the damage caused against the deceased Vicente Juan J. Syquia's remains buried in said memorial park. The damage caused happened upon the removal, for transfer on a different plot of land, of the deceased remains. The damage became apparent upon the opening the vault where the interior walls of the concrete vault showed evidence of total flooding; the coffin was entirely damaged by water, filth, and silt causing the wooden parts to warp and separate and to crack the viewing glass panel located directly above the head and torso of the deceased; and the entire lining of the coffin, the clothing of the deceased, and the exposed parts of the deceased's remains were damaged and soiled by the action of the water and silt and were also coated with filth. Due to the alleged unlawful and malicious breach by the defendant of its obligation to deliver a defect-free concrete vault designed to protect the remains of the deceased and the coffin against the elements which resulted in the desecration of the deceased's grave and in the alternative, because of defendants gross negligence in failing to seal the concrete vault petitioners filed this complaint.

Issue:

    WoN the Manila Memorial Park Cemetery, Inc. is liable for damages?

Ruling:

(Article 1170; 1171; 1338; 1344)

    No, the Manila Memorial Park Cemetery, Inc. is not liable for damages.

    There was no stipulation in the Deed of Sale and Certificate of Perpetual Care and in the Rules and Regulations of the Manila Memorial Park Cemetery, Inc. that the vault would be waterproof. Well settled is the rule that when the terms of the contract are clear and leave no doubt as to the intention of the contracting parties, then the literal meaning of the stipulation shall control.

PNCC v NLRC, G.R. No. 81551, April 27, 1989 CASE DIGEST

 Facts:

    Petitioner and Nicolas Saceda entered into a contract of employment for two years. On January 8, 1984, Saceda completed his contract and the petitioner extended it to January 27, 1984. On February 9, 1984, Saceda was dispatched to Jeddah, Saudi Arabia for immediate repatriation to the Philippines. He was first booked on February 21, 1984, however, Saceda refused to depart because he wanted to wait for the final disposition on the complaint he filed against the petitioner for the payment of his bonus, unused vacation/sick leave, and unpaid wages from December 1, 1983 up to January 27, 1984. The decision of the Saudi labor authorities which was favorable to Saceda was rendered on March 24, 1984. Saceda agreed to be repatriated on March 27, 1984, after the petitioner paid him the award granted by the Saudi labor authorities. Upon his arrival, he found out that 70% of his salary for the period November 16, 1983 to January 15, 1984 was not paid by the petitioner. Saceda then filed a complaint with the Philippine Overseas Employment Administration for non-payment of salary and stand-by pay corresponding to January 27, 1984 to March 27, 1984. He claimed that he was not repatriated soon upon the termination of his contract but was made to wait and remain idle for two months.

Issue:

    WoN the stand-by pay be paid to Saceda?

Ruling:

(Article 1170; 1171; 1338; 1344)

    Yes. It was the petitioners obligation to get Saceda's travel documents ready for his termination of the contract, the petitioner must answer in damages for the delay in Saceda's departure which compelled him to stand-by idle and jobless in a foreign land while waiting for his employer to hand him his ticket and travel papers for his trip home.

Juan Perez v CA, G.R. No. 107737, Oct. 1, 1999 CASE DIGEST

 Facts:

    The petitioner is a usufruct of a parcel of land known as Papaya Fishpond. The petitioner entered into a contract of lease with Luis Keh for a period of five years, renewable for five years. The lease contract stated that Keh cannot sublease and cannot assign rights to anyone. The respondent Luis Crisostomo acquired possession of the aforementioned parcel of land from Keh through an agreement called "pakiao buwis". The petitioners re-acquired possession by force; while Keh surrendered possession to them via a letter.

Issue:

    WoN Crisostomo is a sublessee of the fishpond?

Ruling:

(Article 1244, par. 2; 1168)

    Yes, Crisostomo is a sublessee of the fishpond.

    The lease contract prohibited petitioner Luis Keh, as lessee, from subleasing the fishpond. In entering into the agreement for pakiao-buwis with the private respondent, not to mention the apparent artifice that was his written agreement with petitioner Lee on January 9, 1978, petitioner Keh did exactly what was prohibited of him under the contract — to sublease the fishpond to a third party.

    That the agreement for pakiao-buwis was actually a sublease is borne out by the fact that the private respondent paid petitioners Luis Keh and Juan Perez, through petitioner Tansinsin the amount of annual rental agreed upon in the lease contract between the usufructuaries and petitioner Keh. Petitioner Keh led the private respondent to unwittingly incur expenses to improve the operation of the fishpond. By operation of law, therefore, petitioner Keh shall be liable to the private respondent for the value of the improvements he had made in the fishpond or for P486,562.65 with an interest of six percent (6%) per annum from the rendition of the decision of the trial court on September 6, 1989.

Metropolitan Bank and Trust Company v Rosales, G.R. No. 183204, January 13, 2014 CASE DIGEST

 Facts:

    The respondent and her mother open a joint peso account with one of the petitioners' branches, this was around the year 2000. In May of 2002, the respondent accompanied her client Liu Chiu Fang to open a savings account with the petitioner. The respondent acted as an interpreter on behalf of her client. On March 3, 2003, the respondent opened with the petitioner a joint dollar account. On July 31, 2003, the petitioner issued a "Hold Out' order against the respondents' accounts. On September 3, 2003, the petitioner filed a criminal case for estafa against the respondent, accusing the respondent as the ones responsible for the unauthorized and fraudulent withdrawal from Liu Chiu Fangs's dollar account. The case was dismissed for lack of probable cause. On September 10, 2004, the respondent filed a complaint for breach of obligation and contract against the petitioner. The respondent alleged that they attempted several times to withdraw their deposits but were unable to because petitioner had place their accounts under "Hold Out" status without any explanation as to why it issued saif status. The petitioner alleged that respondent have no cause of action because it had a valid reason for issuing the "Hold Out" order. It averred that due to the fraudulent scheme of the respondent, it was compelled to reimburse Liu Chiu Fang and to file a criminal complaint of estafa against her.

Issue:

    WoN petitioner has an obligation to release the deposit  accounts of the respondent?

Ruling:

(Article 1162; 2176; 2180)

    Yes, the petitioner has an obligation to release the deposit accounts of the respondent.

    Bank deposits, which are in the nature of a simple loan or mutuum, must be paid upon demand by the depositor.

    The "Hold Out" clause applies only if there is a valid and existing obligation from any of the sources of obligation enumerated in Article 1157 of the Civil Code.

    Petitioner failed to show that respondents have an obligation to it under any law, contract, quasi-contract, delict, or quasi-delict.

    Considering that respondent is not liable under any of the five sources of obligation, there was no legal basis for petitioner to issue the "Hold Out" order.

Villegas, et. al. v CA, G.R. Nos. 82562 and 82592, April 11, 1997 CASE DIGEST

 Facts:

    This case originated from a libel suit filed by Antonio V. Raquiza against Antonio J. Villegas, who denied the charge. Villegas left for the United States where he stayed until his death on November 16, 1984. The trial proceeded on absentia by the time of his death. The prosecution had already rested its case two months after his death. The court issued an order dismissing the criminal aspect of the case but reserved the right to resolve its civil aspect. The lower court ordered the estate of Villegas to pay civil damages with regard to the offence. The heirs of Villegas appealed the decision whereby the Court of Appeals affirmed the trials courts' judgement, modified only with respect to the award of damages.

Issue:

    WoN the death of Villegas before final judgement extinguished his civil liability?

Ruling:

(Article 1162; 2176; 2180; RPC Art. 103)

    Yes, the death of Villegas before final judgement extinguished his civil liability.

    The source of Villegas's civil liability in the present case is the felonious act of libel he allegedly committed. If the Court ruled in Bayotas that the death of an accused during the pendency of his appeal extinguishes not only his criminal but also his civil liability unless the latter can be predicated on a source of obligation other than the act or omission complained of, with more reason should it apply to the case at bar where the accused died shortly after the prosecution had rested its case and before he was able to submit his memorandum and all this before any decision could even be reached by the trial court.

    However, the enforcement of a deceased accused's civil liability is dependent on two factors, namely, that it be pursued by filing a separate civil action and that it be made subject to the Rules of Criminal Procedure. Obviously, in the case at bar, the civil action was deemed instituted with the criminal. There was no waiver of the civil action and no reservation of the right to institute the same, nor was it instituted prior to the criminal action. What then is the recourse of the private offended party in a criminal case such as this which must be dismissed in accordance with the Bayotas doctrine, where the civil action was impliedly instituted with it?

    Hence, logically, the court a quo should have dismissed both actions against Villegas which dismissal will not, however, bar Raquiza as the private offended party from pursuing his claim for damages against the executor or administrator of the former's estate, notwithstanding the fact that he did not reserve the right to institute a civil separate civil action based on Article 33 of the Civil Code.

People of the Philippines v Bayotas, G.R. No. 102007, September 2, 1994 CASE DIGEST

 Facts:

    The respondent Rogelio Bayotas was charged with rape and eventually convicted thereof on June 19, 1994. Pending the appeal of his conviction, Bayotas died on February 4, 1992. Consequently, the Supreme Court dismissed the criminal aspect of the appeal. However, it required the Solicitor General to file its comment with regard to the civil liability arising from the offense charged. The OSG expressed his view that the death of Bayotas did not extinguish his civil liability. The counsel of Bayotas opposed the view of the OSG arguing that the death of Bayotas while judgement of conviction was pending appeal extinguishes both criminal and civil penalties.

Issue:

    WoN Bayotas' civil liability is extinguished by his death?

Ruling:

(Article 1162; 2176; 2180; RPC Art. 103)

    Yes, Bayotas's death extinguished his civil liability.

    Death of the accused pending appeal of his conviction extinguishes his criminal liability as well as the civil liability based solely thereon.

    The death of the accused prior to final judgement terminates his civil liability and only the civil liability arising from and based solely on the offence committed, i.e. civil liability ex delicto in seso strictiore.

    Corollarily, the claim for civil liability survives notwithstanding the death of the accused, if the same may also be predicated on a source of obligation other than delict.

Dela Llano v Biong, G.R. No. 182356, December 4, 2013 CASE DIGEST

 Facts:

    The case involves a vehicular accident involving the petitioner and one Joel Primero, wherein the petitioner suffered injuries. The respondent is the employer of Primero. The accident happened on March 30, 2000. On October 16, 2000. the petitioner demanded from the respondent compensation for her injuries, but the respondent refused to pay. The petitioner sued the respondent for damages, alleging that she lost the mobility of her arm as a result of the accident. The respondent maintained that the petitioner had no cause of action against her as no reasonable relation existed between the vehicular accident and her injuries. She pointed out that the illness became manifest one month and one week from the date of the accident.

Issue:

    WoN petitioner can claim compensation for her injuries against the respondent?

Ruling:

(Article 1162; 2176; 2180)

    No, the petitioner cannot claim compensation for her injuries against the respondent.

    The source of obligation in a quasi-delict is the breach or omission of mutual duties that civilized society imposes upon its members, or which arise from non-contractual relations of certain members of society to others. The petitioner must first establish by a preponderance of evidence the three elements of quasi-delict before we determined the respondents' liability as Joel's employer. She should show the chain of causation between Joel's reckless driving and her whiplash injury. The rationale for these graduated levels of analysis is that it is essentially the wrongful or negligent act or omission itself which creates the vinculum juries in extra-contractual obligations.

Venzon v Rural Bank of Buenavista, G.R. No. 178031, August 28, 2013 CASE DIGEST

 Facts:

    The petitioner filed to nullify the foreclosure proceedings and the Tax Declaration issued in the name of the respondent. The petitioner alleged that in 1983 she and her late spouse obtained a Php 5,000.00 loan from the respondent against a mortgage on their house and lot; that she was able to pay Php 2,300.00, thus leaving an outstanding balance of only Php 2,300.00; that sometime in March 1987, she offered to pay the said balance in full but was refused by the respondent; that in March 1987, the respondent foreclosed the mortgage and the property was sold at auction and the respondent being the highest bidder; that the foreclosure proceedings are null and void for lack of notice and publication of the sale; and that the petitioner paid the respondent Php 6,000.00 on October 9, 1995, as evidence by an official receipt issued by the respondent. In its answer, the respondent claimed that the petitioner did not make any payment on the loan; that the foreclosure proceedings were regularly done and all requirements were complied with; and that the Php 6,000.00 paid by the petitioner is utterly false.

Issue:

    WoN the petitioner is entitled to a return of the Php 6,000.00 she paid to the respondent?

Ruling:

(solutio indebiti; 2154-2163)

    Yes, the petitioner is entitled to a return of the Php 6,000.00 she paid the respondent.

    While this may not be validly considered as a redemption of her property as the payment was made long after the redemption period had expired, the respondent had no right to receive the amount. If something is received when there is no right to demand it, and it was unduly delivered through mistake, the obligation to return it arises.

Locsin II v Mekeni Food Corporation, G.R. No. 192105, December, 9, 2013 CASE DIGEST

 Facts:

    The respondent offered the petitioner a position in its organization. In addition to a compensation and benefits package, the respondent offered a car plan, under which one-half of the cost of the vehicle is to be paid by the respondent company and the other half to be deducted from the petitioner's salary. The offer was contained in an Offer Sheet. The petitioner began his work on 17 March 2004 and was furnished by the respondent company with a used car valued at Php 280,000.00. The petitioner paid for his share through salary deductions of Php 5,000.00 each month. The petitioner resigned on 25 February 2006, in his resignation letter he made an offer to purchase his service vehicle by paying the outstanding balance thereon. Both parties could not agree on the terms of the proposed purchase, thus the vehicle was returned on 2 May 2006. The petitioner made personal and written follow-ups regarding his unpaid salaries, commissions, benefits, and offer to purchase his service vehicle. The respondent replied that the company car plan benefit applied only to employees who have been with the company for five years; for this reason, the balance that the petitioner should pay on his service vehicle stood at Php 116,380.00 if he opts to purchase the same. On 3 May 2007, the petitioner filed a complaint for the recovery of monetary claims and recovery of monthly salary deductions which were earmarked for his cost-sharing in the car plan.

Issue:

    WoN the salary deductions made on the service vehicle (the car plan) can be considered as rentals?

Ruling:

(Article 1160; 2142)

    No, the salary deductions made on the service vehicle cannot be considered as rentals.

    From the evidence on record, it is seen that the respondent's car plan offered to the petitioner was subject to no other term or condition than that the respondent company shall cover one-half through deductions from his monthly salary. The respondent has not shown by documentary evidence to suggest that if the petitioner failed to completely cover one-half of the cost of the vehicle, then all the deductions from his salary going to the cost of the vehicle will be treated as rentals for his use thereof while working with the respondent company, and shall not be refunded.

Ollendorff v Abrahamson, G.R. No. 13228, September 13, 1918 CASE DIGEST

 Facts:

    The petitioner is engaged in the business of manufacturing ladies' embroidered underwear for export. On the 10th of September 1915, the petitioner and respondent entered into a contract, whereby the respondent entered the employ of the petitioner and worked for him until April 1916. The respondent, on account of ill health, left the petitioner's employ and went to the United States. Some months after, the respondent returned to Manila as the manager of a corporation which turned out the same class of goods as that of the petitioner. The petitioner commenced this action, the purpose of which is to prevent by injunction any further breach of that part of the respondents' contract of employment by which he agreed to not enter into or engage himself directly or indirectly in a similar competitive business to that of the petitioner for a period of five years from the date of the agreement. The respondent argues that the contract is void for being restrictive of trade.

Issue:

    WoN the contract of employment is valid?

Ruling:

(Article 1159; 1305, 1315)

    Yes, the contract of employment is valid.

    If there is one thing more than another which is essential to the trade and commerce of this country, it is the inviolability of a contract deliberately entered into; and to allow a person of mature age, and not impose upon, to enter into a contract, to obtain the benefit of it, and then to repudiate it and the obligation which he has undertaken, is prima facie, at all events, contrary to the interest of any and every country.

    The public policy which allows a person to obtain employment on certain terms understood by and agreed to by him, and to repudiate his contract, conflicts with, and must, to avail the defendant, for some sufficient reason, prevail over, the manifest public policy, which, as a rule, holds him to his bond.

City of Cebu v Sps. Dedamo, G.R. No. 142971, May 2, 2002 CASE DIGEST

 Facts:

    On 17 September 1993, the petitioner filed a complaint for eminent domain against the respondents. The petitioner alleged that it needed the parcels of land for a public purpose. i.e. public roads. The respondents filed a motion to dismiss the complaint because the purpose of which their property was to be expropriated was not for a public purpose but for the benefit of a single private entity. On 14 December 1994, both parties executed an Agreement wherein they declared that they have partially settled the case. According to the agreement, the trial court appointed three commissioners to determine the just compensation of the lots sought to be expropriated. Thereafter, the commissioners submitted their report. Based on this report, the trial court awarded Php 24,865,930.00 to respondents. Petitioners then filed a motion for reconsideration on the ground that the commissioners' report was inaccurate.

Issue:

    WoN the agreement between the parties is valid?

Ruling:

(Article 1159;1305, 1315)

    Yes, the agreement is valid.

    More than anything else, the parties, by a solemn document, freely and voluntarily agreed upon by them, agreed to be bound by the report of the commission and approved by the trial court. The agreement is a contract between the parties. It has the force of law between them and should be complied with in good faith.

    Records show that the petitioner consented to conform with the valuation recommended by the commissioners. It cannot detract from its agreement now and assail correctness of the commissioner's assessment.

Leung Ben v O'Brien, G.R. No. L-13602, April 16, 1918 CASE DIGEST

 Facts:

    An action was instituted by the respondent to recover from the petitioner the sum of Php 15,000.00 alleged to have been lost by the petitioner to the respondent in a series of gambling, banking, and percentage games conducted during the two of three months prior to the institutions of the suit. Petitioner moved to quash the complaint. Petitioner contends that the action to recover money lost at gaming is no such action as contemplated by law. The law requires that there should be a cause of action arising upon a contract, express or implied.

Issue:

    WoN the statutory obligation to restore money won at gaming is an obligation arising from a contract?

Ruling:

(Article 1158)

    Yes, the obligation to restore money won at gaming is an obligation arising from a contract.

    The obligation to return money lost at play has a decided affinity to contractual obligations; and we believe that it could, without violence to the doctrines of civil law, be held that such obligations is an innominate quasi-contract.

Pelayo v Lauron, G.R. No. 4089, January 12, 1909 CASE DIGEST

Facts:

    Petitioner, a physician, filed a complaint against respondents that on or about the 13th of October 1906, at night, he was called to the house of respondents, and upon arrival, he was requested by them to render medical assistance to their daughter-in-law who was about to give birth. It was found necessary, on account of the difficult birth, to remove the fetus by means of forceps and also to remove the after birth. The just and equitable value of the services rendered by the petitioner was Php 500, to which the respondents refuse to pay without alleging any good reason. In answer to the complaint, the respondents denied all the allegations, that their daughter-in-law had died in consequence of the childbirth, she lived with her husband independently and in a separate house, and that her stay was accidental and due to fortuitous circumstances.

Issue:

    WoN the respondents are bound or obligated to pay the fees due to the petitioner?

Ruling:

(Article 1158)

    No, the respondents are not obligated to pay the fees due to the petitioner.

    Obligations are created by law, by contracts, by quasi-contracts, and by illicit acts and omissions or by those in which any kind of fault or negligence occurs.

    The rendering of medical assistance in case of illness is comprised of the mutual obligations to which spouses are bound by way of mutual support.

    The person bound to pay the fees due to the petitioner for the professional services that he rendered to the daughter-in-law of the respondents during her childbirth is the husband of the patient and not her father-in-law and mother-in-law.

    The fact that it was not the husband who called the petitioner and requested his assistance for his wife is no bar to the fulfillment of the said obligation, as the respondents, in view of the imminent danger to which the life of the patient was at that moment exposed, considered that medical assistance was urgently needed, and the obligation of the husband to furnish his wife with the indispensable services of a physician at such critical moments is specially established by the law, as has been, and compliance therewith is unavoidable; therefore, the petitioner, who believes that he is entitled to recover his fees must direct his action against the husband who is under obligation to furnish medical assistance to his lawful wife in such an emergency.