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1.B. Case: ASJ Corp. V Efren & Maura Evangelista FACTS: Respondents Efren and Maura Evangelista Are Owners of R.M. Sy Chicks, A Business

Respondents owned a business selling chicks and egg products. They hired Petitioner's company for hatching and incubation services. After years of doing business, Respondents fell behind on payments. Petitioner then refused to release the hatched eggs until the full account was settled. Respondents made a partial payment, but Petitioner still insisted on full payment before releasing the products. The court ruled that Petitioner's retention was proper, as Respondents had failed to fully pay their obligation and partial payment does not extinguish the full debt without agreement.

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151 views1 page

1.B. Case: ASJ Corp. V Efren & Maura Evangelista FACTS: Respondents Efren and Maura Evangelista Are Owners of R.M. Sy Chicks, A Business

Respondents owned a business selling chicks and egg products. They hired Petitioner's company for hatching and incubation services. After years of doing business, Respondents fell behind on payments. Petitioner then refused to release the hatched eggs until the full account was settled. Respondents made a partial payment, but Petitioner still insisted on full payment before releasing the products. The court ruled that Petitioner's retention was proper, as Respondents had failed to fully pay their obligation and partial payment does not extinguish the full debt without agreement.

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gg
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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1.B. Case: ASJ Corp.

v Efren & Maura Evangelista

FACTS: Respondents Efren and Maura Evangelista are owners of R.M. Sy Chicks, a business
engaged in selling chicks and egg by-products. Respondents availed the services of ASJ Corp.,
owned by San Juan and his family for hatching and incubation of eggs.

After years of doing business with the ASJ Corp., the respondents delayed payments for the
services of ASJ Corp, prompting owner San Juan to refuse the release of the hatched egg.

The respondents tendered Php 15,000 to San Juan for partial payment which San Juan accepted but
still insisted on the full settlement of respondents’ accounts before releasing the chicks and by-
products. The parties tried to settle the differences with the help of authorities but it failed, the
respondents then filed in the RTC an action for the damages based on the retention of the chicks and
by-products by the petitioners.

ISSUE: WON the petitioner’s retention of the chicks was proper

HELD: Yes.Petitioners contend that the retention was justified and did not constitute an abuse of
rights since it was respondents who failed to comply with their obligation. Respondents offer to
partially satisfy their accounts is not enough to extinguish their obligation. Under Article 1248of the
Civil Code, the creditor cannot be compelled to accept partial payments from the debtor, unless
there is an express stipulation to that effect.

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