National Grains Authority v. The Intermediate Appellate Court

Summary

Leon Soriano delivered 630 cavans of palay to the National Grains Authority (NFA) after being given a quota of 2,640 cavans, but NFA refused payment claiming he was not a bona fide farmer. Soriano sued for specific performance and collection. The core legal issue was whether a valid contract of sale existed between the parties. The Supreme Court affirmed lower court decisions, holding that a contract of sale was perfected when NFA accepted Soriano's offer by granting him a quota, constituting a meeting of minds under Article 1475 of the Civil Code. The Court ruled that NFA's internal procedural requirements did not affect the perfected contract, and that both parties were bound to perform their mutual obligations. The decision established that contracts of sale are consensual and perfected upon agreement on the subject matter and price, regardless of whether goods are actually delivered or accepted according to internal procedures.