Asj Corporation v. Sps. Efren & · G.R. 158086

Petitioner: Asj Corporation
Respondent: Sps. Efren & Maura Evangelista
Citation: G.R. No. 158086
Court: Supreme Court
Division: Second Division
Ponente: Quisumbing, J.
Decided: February 14, 2008

Summary

This commercial dispute involved R.M. Sy Chicks' claim against ASJ Corporation and Antonio San Juan for unjustified retention of hatched chicks and egg by-products worth over P500,000. The Supreme Court distinguished between justified retention due to unpaid service fees (P102,336.80 outstanding balance) and unjustified threats that prevented retrieval of subsequent batches. Applying the doctrine of piercing corporate veil, the Court held San Juan personally liable alongside his corporation. While recognizing petitioners' right to demand payment before delivery under reciprocal contract obligations, the Court found San Juan's threats constituted abuse of rights under Civil Code Article 19. The decision balanced commercial law principles on contract performance with civil law protections against abuse of rights, awarding reduced temperate damages to respondents while requiring them to pay their legitimate service fee obligations.

Statutes applied

Civil Code, Art. 19

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By the Intellegal Editorial Board · February 14, 2008

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