J. C. Choy v. Genaro Heredia

Summary

This 1908 case involved a construction contract dispute between Go-Sitco and Genaro Heredia. After completing two houses, the parties executed a document on August 21, 1903, acknowledging P2,100 balance due and P400 additional payment contingent on a 3-year warranty. When Go-Sitco sued to collect both amounts, the Supreme Court affirmed the lower court's award of P1,100 (after crediting P1,000 payment) but denied the P400 warranty payment for failure to prove warranty compliance. The decision established important principles regarding contract interpretation, the effect of express acceptance without protest as acknowledgment of substantial performance, and the burden of proving warranty conditions. The case demonstrates early Philippine jurisprudence on construction contracts and the Civil Code's application to contractual obligations.