Spouses Rene v. Garcia International Art Gallery

Summary

The Supreme Court affirmed lower courts' finding that a perfected contract of sale existed between Spouses Cuyco and Garcia International Art Gallery for furniture and fixtures. Despite petitioners' claim that items were delivered for demonstration only and that checks were for imported items never delivered, the Court found that their contemporaneous acts—retaining items, issuing checks, and acknowledging liability in letters—established a consensual contract under Articles 1458 and 1475 of the Civil Code. The Court emphasized that factual determinations regarding the true nature of the transaction were not reviewable under Rule 45, and that preponderant evidence supported the respondent's claim. The case demonstrates how courts analyze party conduct to determine contractual intent in sales transactions.