R. Francis Adams v. Sociedad Naton

Summary

This 1919 Supreme Court case involved a construction contract dispute where contractor Adams sued Sociedad Naton and surety Aldea for unpaid installments totaling P7,409. Adams contracted to build for P11,163.99 but was required to purchase lumber from Hontiveros, who failed to deliver despite Adams' efforts. When Adams attempted alternative sourcing, Sociedad Naton objected, causing work suspension. The Supreme Court affirmed judgment for Adams, finding defendants' insistence on unavailable Hontiveros lumber constituted breach making payment of installments due unconditional. However, the Court dismissed co-plaintiff Smith for lack of standing as mere collection agent rather than contract assignee. The decision established that while building contract owners retain absolute abandonment rights under Civil Code Article 1594, they remain liable for installments due and any delay-caused damages when their obstruction prevents contract performance.