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Manlar vs. Deyto

Manlar Rice Mill filed a case against Ang and Deyto to hold them solidarily liable for an unpaid rice supply contract. The trial court ruled both defendants were liable. The appellate court concluded there was no basis to hold Deyto liable as the evidence did not show her participation in the transactions between Ang and Manlar. The Supreme Court affirmed the appellate court's ruling, finding the preponderance of evidence indicated it was Ang alone who entered into the contract with Manlar based on the checks being from Ang's individual bank account. As contracts generally only bind the parties involved, and Deyto was not a party to the rice supply contract, Manlar could only sue Ang and not hold Deyto solidarily liable

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296 views2 pages

Manlar vs. Deyto

Manlar Rice Mill filed a case against Ang and Deyto to hold them solidarily liable for an unpaid rice supply contract. The trial court ruled both defendants were liable. The appellate court concluded there was no basis to hold Deyto liable as the evidence did not show her participation in the transactions between Ang and Manlar. The Supreme Court affirmed the appellate court's ruling, finding the preponderance of evidence indicated it was Ang alone who entered into the contract with Manlar based on the checks being from Ang's individual bank account. As contracts generally only bind the parties involved, and Deyto was not a party to the rice supply contract, Manlar could only sue Ang and not hold Deyto solidarily liable

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Lady Bancud
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© © All Rights Reserved
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15. MANLAR RICE MILL VS.

DEYTO (715 SCRA 81)

FACTS: Ang entered into a rice supply contract with


Manlar, with the former purchasing rice from the latter
and the transaction was covered by nine postdated
checks issued by Ang from her personal bank/checking
account. The first two checks were dishonored for
having been drawn against insufficient funds; the
remaining seven checks were dishonored for being
drawn against a closed account. Manlar made oral and
written demands upon both Deyto and Ang, which went
unheeded. During the time demand was being made
upon Deyto, she informed Manlar, through its Sales
Manager Pua, that Ang could not be located.

Manlar filed a Complaint for sum of money against


Deyto and Ang before the RTC of Quezon City seeking
to hold Deyto and Ang solidarily liable on the rice
supply contract. TC ruled that both defendants should
be held solidarily liable for the unpaid and outstanding
Manlar account.
Upon appeal, the CA concluded that there is no legal
basis to hold Deyto solidarily liable with Ang for what
the latter may owe Manlar. The evidence failed to
indicate that Deyto had any participation in the
supposed transactions between her daughter and
Manlar. Petitioner filed a Petition for Review on
Certiorari to the Supreme Court.

ISSUE: Whether or not the CA is correct in concluding


that there is no legal basis to hold Deyto solidarily liable
with Ang for what the latter may owe Manlar?

HELD: Yes. The evidence does not support Manlars


view that both Deyto and Ang contracted with Manlar
for the delivery of rice on credit. Preponderance of
evidence indicates that it was Ang alone who entered
into the rice supply agreement with Manlar. The
documentary evidence shows that the subject checks
were issued from a bank account in China bank del
Monte branch belonging to Ang alone.

As a general rule, a contract affects only the parties to


it, and cannot be enforced by or against a person who
is not a party thereto. It is a basic principle in law that
contracts can bind only the parties who had entered
into it; it cannot favor or prejudice a third person.

Under Article 1311 of the civil code, contracts take


effect only between the parties, their assigns and heirs.
Thus, Manlar may sue Ang, but not Deyto, who the
court finds to be not a party to the rice supply contract.

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