Herman (Boy) Mercado v. Romeo · G.R. 200524

Petitioner: Herman (Boy) Mercado
Respondent: Romeo Alipio
Citation: G.R. No. 200524
Court: Supreme Court
Division: Second Division
Decided: March 14, 2018

Summary

This case involves a construction subcontract payment dispute where Romeo Alipio (R.S. Construction) sued Bear Builders for unpaid balance of P280,253.57 from construction work performed at Taal Splendido project. Bear Builders argued that payment was subject to suspensive conditions requiring LGC's verification and approval. The Supreme Court ruled that unilaterally imposing suspensive conditions without the other party's consent violates the principle of mutuality of contracts under Article 1308 of the Civil Code. The Court found that since LGC had paid Bear Builders, this indicated that Alipio's work had been verified and approved. The burden of proving payment rested on Bear Builders who failed to present adequate documentary evidence. The Court affirmed the award of P280,253.57 with modified interest rates: 12% per annum from complaint filing to June 30, 2013, then 6% per annum thereafter, following BSP regulations. This case establishes important precedent on contractual mutuality and burden of proof in payment disputes.

Statutes applied

Civil Code, Art. 1308

Related cases

Other Philippine cases on the same provisions and issues.

Gf Equity v. Arturo Valenzona G.R. No. 156841
United Coconut Planters Bank v. Editha F. Ang G.R. No. 222448
Philippine National Bank v. Spouses Enrique Manalo & Rosalinda Jacinto G.R. No. 174433
Spouses Bayani H. Andal v. Philippine National Bank G.R. No. 194201
Fedman Development Corporation v. Federico Agcaoili G.R. No. 165025
Spouses Ponciano Almeda v. The Court of Appeals G.R. No. 113412
Philippine National Bank v. The Hon. Court of Appeals G.R. No. 88880
Philippine Development & Industrial Corporation v. Equitable Pci Bank (Now Known As Banco de Oro-Epci G.R. No. 207242

By Intellegal Editorial Board · March 14, 2018

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