Heirs of the Deceased Carmen Cruz-Zamora v. Multiwood International

Summary

This case involved a commission dispute between agent Carmen Cruz-Zamora and principal Multiwood International, Inc. under a 1987 Marketing Agreement. Zamora claimed 10% commission for soliciting interior construction contracts for major hotels, arguing these fell within the agreement's scope. The RTC initially ruled in her favor based on unoffered documentary evidence suggesting partial payments. However, the Court of Appeals and Supreme Court reversed, holding that the Marketing Agreement's clear terms limited commissions to product sales only, not construction services. The Supreme Court emphasized strict application of contract interpretation rules and evidence procedures, ruling that courts cannot read additional terms into unambiguous contracts. The decision reinforces the parol evidence rule and the requirement for formal offer of documentary evidence. Zamora's heirs ultimately received nothing and were liable for her unliquidated advances.