- Petitioner
- Joseph Chan
- Respondent
- Bonifacio S. Maceda, Jr.
- Citation
- G.R. No. 142591
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Sandoval-Gutierrez, J.
- Decided
- April 30, 2003
Summary
Respondent Maceda sued the Chan siblings for damages, claiming they failed to return construction materials deposited in their warehouse by Moreman Builders. The materials were for Maceda's hotel project which Moreman failed to complete on schedule. After Maceda won a separate case against Moreman for contract rescission, he sought to recover the deposited materials but the Chans claimed Moreman had already withdrawn them. The RTC and CA awarded Maceda P4.479 million in damages based on ex-parte proceedings after the Chans were declared in default. However, the Supreme Court reversed, finding fatal procedural errors in the case's reinstatement and, more importantly, that Maceda failed to prove any contract of deposit existed between him and the Chans, or that materials were actually in their warehouse when demanded. The Court emphasized that actual damages must be proved with reasonable certainty, not based on speculation, and that without privity of contract, the Chans had no obligation to Maceda regarding the materials.