- Petitioner
- Mariano Limjap
- Respondent
- J. Machuca & Co.
- Citation
- G.R. No. 13210
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- Fisher, J.
- Decided
- August 9, 1918
Summary
This landmark 1918 case established important precedent regarding contractor liability for hidden defects in construction contracts. Limjap contracted with J. Machuca & Co. for mausoleum construction requiring reinforced concrete pedestal. Despite defendant's false assurances of compliance, the pedestal lacked reinforced concrete and later developed structural problems. The Supreme Court affirmed liability under Civil Code Article 1591, holding that acceptance of completed work does not bar claims for hidden defects that cannot be detected by ordinary inspection. The decision established that contractors remain liable for construction defects even after delivery and acceptance, and that owners have a duty to minimize damages through prompt repairs rather than allowing total collapse.