Rosalina Ricafuente v. Oriental Construction

Summary

This case involves a contract of sale dispute between individual proprietor Rosalina Ricafuente (doing business as Michael's Electrical Supply) and Oriental Construction and Electrical Supply Co., Inc. Ricafuente purchased P977,330.99 worth of electrical supplies on credit through phone orders between July-November 2010, with goods delivered to her brother-in-law's store per her instructions. Despite sales invoices stipulating 30-day payment terms and 1% monthly interest on overdue accounts, Ricafuente failed to pay after demand. She claimed inability to verify purchases due to business relocation and closure. The Supreme Court affirmed lower courts' findings that a perfected contract of sale existed based on credible testimony of respondent's accounting assistant who confirmed phone orders and receipt. The Court applied Civil Code provisions on consensual contracts and stipulated interest, ordering payment of principal amount plus 12% annual interest from demand date. However, it deleted attorney's fees award for lack of sufficient justification of bad faith, emphasizing courts must provide proper legal basis for such awards under Article 2208.