Jl Investment v. Tendon · G.R. 148596

Petitioner: Jl Investment
Respondent: Tendon Philippines
Citation: G.R. No. 148596
Court: Supreme Court
Division: Second Division
Ponente: Inc., J.
Decided: January 22, 2007

Summary

JL Investment hired SMCC to construct a building, and SMCC subcontracted TPI for concrete piles worth P4,118,000. When SMCC failed to fully pay TPI the P1,389,330 balance, TPI sued all parties. The RTC absolved JL Investment, finding it had already paid SMCC for the pile driving work before TPI's demand. The CA reversed, holding JL Investment solidarily liable under Article 1729 of the Civil Code, which protects material suppliers by allowing them to collect from building owners up to amounts owing to contractors. The Supreme Court affirmed the solidary liability but granted JL Investment's cross-claim for reimbursement from SMCC to prevent unjust enrichment. The case establishes that Article 1729 creates direct liability for owners to suppliers regardless of specific payment allocations, but owners retain reimbursement rights against defaulting contractors.

Statutes applied

Civil Code, Art. 1729

Related cases

Other Philippine cases on the same provisions and issues.

Del Monte Philippines v. Napoleon N. Aragones G.R. No. 153033
Grandspan Development Corporation v. Franklin Baker G.R. No. 251463
Century Iron Works v. Far Eastern University G.R. No. 217329
Noell Whessoe v. Independent Testing Consultants G.R. No. 199851

By the Intellegal Editorial Board · January 22, 2007

Search Philippine case law on Intellegal →

AI-assisted case analysis — for research only. Verify against the official decision. A research aid, not legal advice; using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer. Verify every holding and citation against the official decision (Supreme Court E-Library / Official Gazette) before relying on it.