Manlar Rice Mill v. Lourdes L. Deyto

Summary

This case involves a rice supply contract dispute where Manlar Rice Mill sought to hold both a daughter (Jennelita Ang) and her mother (Lourdes Deyto) solidarily liable for P3,843,220.00 in dishonored checks. The Supreme Court affirmed the Court of Appeals' reversal of the trial court, ruling that contracts affect only the parties to them and cannot be enforced against non-parties under Article 1311 of the Civil Code. The evidence showed only Ang, not her mother Deyto, was a party to the rice supply contract, as the checks came from Ang's personal account and there was no written agreement making Deyto solidarily liable. The Court emphasized that solidary liability cannot be lightly inferred and must be expressly stated, legally required, or necessitated by the obligation's nature. The decision reinforces the fundamental principle that contractual obligations bind only the contracting parties and their successors-in-interest.