Tangco v. Court of Appeals

Summary

This case involved a construction contract dispute where architect Marquez contracted with Mrs. Tangco to build a residential building for P45,000, then subcontracted the work to Suñga for P42,000. When payment disputes arose, Suñga sued Mrs. Tangco directly for unpaid balances and extra work totaling P7,620. The trial court dismissed the case, finding no privity of contract between Mrs. Tangco and Suñga. The Court of Appeals reversed, holding Mrs. Tangco liable for all claimed amounts. The Supreme Court partially affirmed, ordering payment of P400 balance and P1,300 for approved extras, but reversed the P5,920 award for additional extra work, ruling that Mrs. Tangco could not be held liable for work not done at her request or with her knowledge of payment obligation. The decision clarifies the limits of liability under construction contracts and the requirements for quasi-contractual obligations.