- Petitioner
- Del Monte Philippines
- Respondent
- Napoleon N. Aragones
- Citation
- G.R. No. 153033
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Carpio Morales, J.
- Decided
- June 23, 2005
Summary
This case clarified the distinction between contracts of sale and contracts for a piece of work under Civil Code Article 1467. DMPI contracted with MEGA-WAFF for warehouse pavement installation, who sub-contracted with Aragones for specialized S-shaped concrete blocks. When MEGA-WAFF failed to pay Aragones, he sought direct payment from DMPI under Article 1729, which protects laborers and materialmen by allowing direct action against project owners. The Supreme Court held that the Supply Agreement was a contract for piece of work, not sale, because the blocks were specially manufactured per specific order and design. The Court applied Article 1729 to create constructive contractual privity between DMPI and Aragones, finding DMPI liable for the unpaid amount despite lack of direct contractual relationship. The decision reinforces protection for sub-contractors against potential connivance between owners and general contractors.