G.R. No.
110295 October 18, 1993
COCA-COLA BOTTLERS PHILIPPINES, INC.,
vs.
THE HONORABLE COURT OF APPEALS (Fifth Division) and MS. LYDIA
GERONIMO, respondents.
Angara, Abello, Concepcion, Regala & Cruz Law Offices for petitioner.
Alejandro M. Villamil for private respondent.
FULLTEXT HERE:
https://lawphil.net/judjuris/juri1993/oct1993/gr_110295_1993.html
FACTS:
Lydia L. Geronimo filed a complaint against the petitioner in the Regional
Trial Court, claiming damages. She ran Kindergarten Wonderland Canteen,
selling soft drinks like Coke and Sprite to students and the public. Some
parents complained about finding fiber-like material and foreign particles in
the drinks. Lydia checked her stock and confirmed the issue. She had the
drinks examined at the Regional Health Office, and they were declared
"adulterated" by the Department of Health. This discovery significantly
affected her soft drink sales.
Coca-Cola filed a motion to dismiss Lydia Geronimo's complaint, arguing
that she hadn't exhausted administrative remedies and that the claim was
prescribed.
Lydia countered, stating her complaint wasn't about administrative matters
and was filed within the prescribed time for injuries to her rights.
The trial court sided with Coca-Cola, stating the administrative remedy
wasn't adequate and that the complaint should've been filed within six
months based on contractual relations. Lydia's motion for reconsideration
was denied, so she petitioned the Court, leading to the case being referred
to the Court of Appeals.
The Court of Appeals overturned the trial court's decision, ruling that
Lydia's complaint was about negligence in manufacturing adulterated food,
falling under quasi-delict, with a four-year prescriptive period.
Despite the contract between the parties, the Court stated that contractual
relations didn't prevent an action for negligence arising from the contract's
performance.
COCA-COLA CONTENTION:
Coca Cola argues that Lydia Geronimo's complaint is
primarily based on a breach of implied warranties under the law on sales,
not on any wrongful conduct by Coca-Cola. They claim that because there's
a contractual relationship between them, the law on quasi-delicts doesn't
apply, and the complaint should've been filed within six months of delivery
of the soft drinks.
LYDIA CONTENTION:
Lydia argues that under the Civil Code, she can either
withdraw from the contract or demand a reduction of the price with
damages for breach of implied warranties. She asserts that her complaint
isn't about rescinding or reducing the contract price but is for damages
arising from Coca-Cola's negligence in manufacturing contaminated food
items.
ISSUE:
WON the action for damages by the proprietress against the soft drinks
manufacturer should be treated as one for breach of implied warranty under
article 1561 of the CC which prescribes after six months from delivery of the
thing sold.
RULING:
Petition Denied.
The SC agrees with the CA’s conclusion that the cause of action in the case
at bar is found on quasi-delict under Article 1146 of the CC which prescribes
in four years and not on breach of warranty under Article 1562 of the same
code. This is supported by the allegations in the complaint which refers to
the reckless and negligent manufacture of "adulterated food items intended
to be sold for public consumption."
The Court agrees with Lydia, stating that her complaint is indeed based on
quasi-delict, as evidenced by allegations of reckless and negligent
manufacturing of adulterated food items. It concludes that the prescriptive
period for quasi-delicts applies, allowing Lydia to file her complaint within
four years, not six months as argued by Coca-Cola.
The buyer can also seek annulment of the contract in case of error or fraud,
following the ordinary rules on obligations. Fraud responsibility applies to all
obligations, and waiving future fraud action is invalid. Negligence
responsibility is also applicable, but courts may regulate liability based on
circumstances. Those guilty of fraud, negligence, or failing to meet
obligations are liable for damages.
The seller could also be liable for quasi-delict under Article 2176 of the Civil
Code, and the buyer can bring an action based on it. Although a pre-existing
contract generally prevents quasi-delict application, liability may arise from
quasi-delict, meaning acts breaking the contract may also constitute a tort.
Liability for quasi-delict can exist despite contractual relations.
Under American law, a manufacturer or seller of injury-causing products
may be liable based on negligence, breach of warranty, tort, or other
grounds like fraud or misrepresentation. Quasi-delict, akin to tort, includes
negligence and intentional criminal acts like assault and battery, false
imprisonment, and deceit.
Therefore, the petition by Coca-Cola is denied due to lack of merit, with
costs against Coca-Cola.
