Nutrimix Feeds Corporation v. Court of Appeals

Summary

Nutrimix Feeds Corporation sued Spouses Evangelista for P766,151 in unpaid animal feeds. Evangelistas counterclaimed that contaminated feeds caused mass death of their livestock, constituting breach of warranty against hidden defects under Civil Code Articles 1561-1566. The trial court ruled for Nutrimix, finding insufficient proof of contamination at delivery. The Court of Appeals reversed, accepting that feeds were defective. The Supreme Court reinstated the trial court decision, holding that the three-month gap between delivery (July 1993) and testing (October 1993) made it impossible to prove defects existed when the product left Nutrimix's control. The Court emphasized that warranty breach requires proof that defects existed at time of sale, and circumstantial evidence of animal deaths was insufficient without establishing the causal link between delivered feeds and the deaths.