Engineering & Machinery Corporation v. Court of Appeals

Summary

Engineering & Machinery Corporation contracted to fabricate and install an air-conditioning system in Almeda's building for P210,000 in 1962. After Almeda reacquired his building in 1971, he discovered extensive defects and missing components. The Supreme Court held this was a contract for a piece of work under Article 1713 of the Civil Code, not a sale contract, since the contractor's business involved custom fabrication per specifications rather than off-the-shelf sales. The Court determined the complaint alleged breach of the written contract itself rather than warranty violations, making the ten-year prescription period under Article 1144 applicable. Since the suit was filed within this period, it was timely. The Court affirmed that the contractor failed to install required components and deviated from specifications, causing system ineffectiveness that necessitated 35 additional window units. The decision establishes important precedent distinguishing sale contracts from work contracts and clarifies applicable prescription periods.