Case No.

RONQUILLO vs. CA
G.R. No. L-55138, September 28, 1984

DOCTRINE:
Individual obligation creates a several obligation

FACTS:
Ronquillo was one of defendants of the 4 defendants filed by private
respondent, for the collection of the sum of P17,498.9. The other
defendants were Offshore Cater trade Inc., Johnny Tan and Pilar
Tan. The amount of P117,498.98 sought to be collected represents
the value of the checks issued by said defendants in payment for
foodstuffs delivered to and received by them. The said checks were
dishonored by the drawee bank. Private respondent (then plaintiff
filed a Motion for Execution on the ground that defendants failed to
make the initial payment. Meanwhile, or more specifically on March
19, 1980, a writ of execution was issued for the satisfaction of the
sum of P82,500.00 as against the properties of the defendants
(including petitioner), "singly or jointly liable." On March 20, 1980,
Special Sheriff Eulogio C. Juanson of Rizal, issued a notice of
sheriff's sale, for the sale of certain furnitures and appliances found in
petitioner's residence to satisfy the sum of P82,500.00.

ISSUE:
Whether an obligation described as “individually and jointly” is
enforceable against one of the obligors

RULING:
Based on the parties' compromise agreement, defendants individually
and jointly agree to pay within a period of six months. The term
"individually" has the same meaning as "collectively", "separately",
"distinctively", respectively or "severally". An agreement to be
"individually liable" undoubtedly creates a several obligations, and a
"several obligation"... is one by which one individual binds himself to
perform the whole obligation. The obligation in the case at bar being
described as "individually and jointly", the same is therefore
enforceable against one of the numerous obligors. Petition is hereby
DISMISSED.
Case No
METROPOLITAN BANK AND TRUST COMPANY vs. ANA GRACE
ROSALES AND YUK TO
G.R. NO. 183204, JANUARY 13, 2014

DOCTRINE:
Bank deposits, which are in the nature of a simple loan or mutuum,
must be paid upon demand by the depositor.

FACTS:
On March 3, 2003, respondents opened with petitioner’s Pritil-Tondo
Branch a Joint Dollar Account with an initial deposit of US$14,000.00.
On July 31, 2003, petitioner issued a “Hold Out” order against
respondents’ accounts. On September 3, 2003, petitioner, through its
Special Audit Department Head Antonio Ivan Aguirre, filed before the
Office of the Prosecutor of Manila a criminal case for Estafa through
False Pretences, Misrepresentation, Deceit, and Use of Falsified
Documents. Respondent Rosales, however, denied taking part in the
fraudulent and unauthorized withdrawal from the dollar account of Liu
Chiu Fang.December 15, 2003, the Office of the City Prosecutor of
Manila issued a Resolution dismissing the criminal case for lack of
probable cause. On September 10, 2004, respondents filed before
the RTC of Manila a complaint for Breach of Obligation and Contract
with Damages.

ISSUES:
A. Whether or not the petitioner should be liable for breach of
contract.

RULING:
The petition is denied for lack of merit. Petitioner is guilty of breaching
their contract with the respondent as they unjustly refused to allow
the respondents to withdraw their deposits with the petitioner. With
that breach in contract, the petitioners are liable for damages.
Moreover, the petitioner’s reliance on their “Hold Out” clause is in
misplaced.
Case No.
JOSEPH SALUDAGA vs. FAR EASTERN UNIVERSITY
G.R. NO. 179337, APRIL 30, 2008

DOCTRINE:
Institutions of learning must also meet the implicit or "built-in"
obligation of providing their students with an atmosphere that
promotes or assists in attaining its primary undertaking of imparting
knowledge.

FACTS:
Petitioner was shot by the respondent’s security guard, Alejandro
Rosete. Fortunately, respondent was not fatally injured. Petitioner
later then filed a complaint against respondent for breaching their
contract of providing a safe and secure learning environment as he
was shot by the respondent’s own security guard. Respondent then
filed a Third-Party complaint against the security agency they were
contracted with,
The trial court then ruled in favor of the petitioner. Galaxy is also
ordered to pay the petitioner jointly with the respondents. CA ruled to
reverse and set aside the decision of the RTC and dismiss the case.
Aggrieved, petitioner filed petition with SC.

ISSUE:
Whether or not FEU may be held liable for damages for a breach of
contract.

RULING:
Yes. FEU must be held liable for damages as they breached the
implied contract of providing students a safe and secure environment
for learning. It is well settled in culpa contractual that the mere proof
of the existence of the contract and failure of its compliance is
enough to justify a right of relief. The fact that petitioner was shot
inside the school premises and shot by the security guard who was
tasked to ensure the safety of its students is enough to be a prima
facie of the respondent’s failure to comply with its obligation. It is
essential in the award of damages that the claimant must have
satisfactorily proven during the trial the existence of the factual basis
of the damages and its causal connection to defendant's acts.”
Therefore, the petition is granted, and the decision of the CA is
reversed and set aside. The decision of the RTC is affirmed with
modifications.
Case No.
MANILA ELECTRIC COMPANY vs. MATILDE MACABAGDAL
RAMOY, ET AL
G.R. NO. 158911, MARCH 4, 2008

DOCTRINE:
In culpa contractual, the mere proof of the existence of the contract
and the failure of its compliance justify, prima facie, a corresponding
right of relief.

FACTS:
NPC then ordered MERALCO to disconnect the electrical power
supply to all of the residential and commercial buildings beneath the
NPC transmission lines. After ocular inspections ordered by the court,
it has been proven that the property of the respondent was indeed
outside of the disputed property of the NPC. RTC decided in favor of
MERALCO by dismissing respondents’ claim for moral and
exemplary damages but ordered MERALCO to reconnect the power
supply of the respondents. Respondents then appealed to the CA
where the CA decided that MERALCO is at fault for not requiring
NPC to show a writ of execution or demolition and not coordinating
with the proper authorities before complying with NPC. Thus, CA held
petitioner liable for moral and exemplary damages. Aggrieved,
petitioners filed with the SC a petition for certiorari.

ISSUE:
Whether or not MERALCO is liable for damages.

RULING:
Yes. MERALCO is liable for damages. MERALCO admits that they
and respondents are under a Service Contract. The respondents’
action against MERALCO is based on culpa contractual for the unjust
service interruption. The utmost care and diligence required of
MERALCO necessitates such great degree of prudence on its part,
and failure to exercise the diligence required means that MERALCO
was at fault and negligent in the performance of its obligation.
Therefore, MERALCO is held liable for damages. WHEREFORE, the
petition is partly granted. The CA decision is affirmed with
modification.
Case No.
FAUSTINO CRUZ vs. J. M. TUASON & COMPANY, INC.
G.R. NO. L-23749, APRIL 29,1977

DOCTRINE:
A presumed quasi-contract cannot emerge as against one party when
the subject matter thereof is already covered by an existing contract
with another party.

FACTS:
Respondents availed of the petitioner’s services to act as
intermediary between them and the Deudors to settle a civil case
involving parcels of land. An agreement was formed between Tuason
and the Deudors and duly approved by the court. Later on, Cruz
alleges that respondent promised him a portion of the disputed lot
once the negotiation has been finalized but the respondent did not
convey him the promised portion of the land. Petitioner stated that
this agreement was made in consideration for his services. Petitioner
further alleges that respondent was unjustly enriching themselves at
petitioner’s expense as petitioner made improvements to the land
which the respondents benefitted from.

ISSUE:
Whether or not the quasi-contract of the petitioner with petitioner
should still stand even if the subject of the contract is already covered
by another contract with another party.

RULING:
No. The Supreme Court stated in this case that “it is obvious that a
presumed quasi-contract cannot emerge as against one party when
the subject matter thereof is already covered by an existing contract
with another party. Predicated on the principle that no one should be
allowed to unjustly enrich himself at the expense of another, Article
2124 creates the legal fiction of a quasi-contract precisely because of
the absence of any actual agreement between the parties
concerned.” Therefore, the case is now dismissed.