Delta Motor Corporation v. Eduarda Samson Genuino

Summary

Delta Motor Corporation contracted to sell black iron pipes to the Genuino family for their ice plant in July 1972. After the Genuinos made down payments but delayed accepting delivery due to construction issues, Delta attempted to increase prices significantly when delivery was demanded three years later. The trial court favored Delta and ordered contract rescission, but the Court of Appeals reversed, finding Delta should honor original prices. The Supreme Court affirmed, ruling that Delta waived its right to rescission by not acting when delivery was initially refused and by only demanding higher prices rather than claiming breach. The Court held that once the offers were accepted within the specified period, valid contracts were formed that neither party could unilaterally modify, and Delta's conduct did not constitute substantial breach warranting rescission under Article 1191 of the Civil Code.