Chevron Philippines v. Looyuko

Summary

Chevron Philippines sued Alberto Looyuko and others for P7,381,510.70 in unpaid petroleum products and services delivered to Noah's Ark Sugar Refinery from April-November 1997. The RTC ruled for Chevron, finding Looyuko liable as the refinery's proprietor despite his denials. The CA reversed, finding no perfected contract due to lack of consent and proper authentication of delivery receipts. The Supreme Court granted Chevron's petition, holding that the 105 invoices were actionable documents that respondents failed to properly contest. Looyuko's admission of proprietorship, combined with his failure to deny his employees' authority to receive deliveries, established liability under agency by estoppel. The Court reinstated the RTC decision but modified the interest rate from 24% to graduated rates of 12% then 6%, and attorney's fees to 20% of principal per invoice terms. The case demonstrates the importance of proper pleading in contesting actionable documents and the doctrine of agency by estoppel in commercial transactions.