Tuesday, September 23, 2014

[CASE DIGEST] SONGCO v. SELLNER (G.R. No. 11513)


December 4, 1917
 
Ponente: Street, J.

FACTS:

·         George C. Sellner was the owner of a farm at Floridablanca, Pampanga. Right beside his farm was another farm owned by Lamberto Songco. On or about December 1915, both properties had a considerable quantity of sugar cane ready to be cut.

·         The nearest sugar central where sugar canes were milled was located in Dinalupijan. Sellner wanted his harvest to be milled here, but the owners of the sugar central could not accommodate him. The said sugar central, however, was going to mill Songco's cane.

·         Sellner offered to buy Songco's canes. He did so in order to include the canes harvested from his own farm with that of Songco's and have these milled at the aforecited sugar central. Part of the deal was for Songco to grant Sellner a right of way to his farm. 

·         Songco sold his potential harvest to Sellner for P12,000. Songco estimated that the canes from his farm would produce 3,000 piculs of sugar. Sellner agreed to pay in three installments amounting to P4,000 each. 

·         Sellner was able to complete the two installments. However, he refused to pay the third and final installment. This prompted Songco to file an action against Sellner. 

·         As a defense, Sellner denied the allegations and posited that his deal with Songco was marred by fraudulent misrepresentation. It turned out that instead of yielding 3,000 piculs of sugar as estimated, the canes from Songco's farm only yielded 2,017 piculs, gross, and after the toll for milling was deducted the net left to Sellner was very much less. Sellner also said that Songco refused to warrant his estimate. 

·         The lower court ruled in favor of Songco, ordering Sellner to pay the final P400 installment. The court nonetheless dismissed the attachment of some of Sellner's properties because, as proven in court, Sellner was a wealthy man who had no reason to convey away Songco's property. The court also ordered Songco to pay damages to Sellner equivalent to the amount actually paid out by Sellner in procuring the dissolution of the attachment. Hence, the instant petition by Songco..

RULING: 

Lower court ruling affirmed.

Whether or not Songco was disingenuous and uncandid with his estimate of the yields of his farm produce. – YES.

·         It was fairly shown by the evidence that Songco knew at the time he made the representation in question that he was greatly exaggerating the probable produce of his fields, and it was impossible to believe that his estimate honestly reflected his true opinion. He knew what these same fields had been producing over a long period of years; and he knew that, judging from the customary yield, the harvest in 1915 would fall far below the amount stated.

Whether or not the contract of sale should be voided for fraud. – NO.

·         The law allows considerable latitude to seller's statements, or dealer's talk. The refusal of Songco to warrant his estimate should have admonished Sellner that the said estimate was put forth as a mere opinion. Granted, a misinterpretation upon a mere matter of opinion is not an actionable deceit, nor is it a sufficient ground for voiding a contract as fraudulent. 

·         By relying on Songco's estimate, Sellner bound himself to the terms stipulated in their contract. Since Sellner did so at his own peril, he must therefore take the consequences of his own imprudence. As such, he must pay Songco the third and final installment worth P400.

Whether or not Sellner's properties should be levied in favor of Songco. – NO. 

·         As proven in court, Sellner was a wealthy man ("a man of large resources") with no interest in conveying away Songco's property as alleged.

·         The SC affirmed the lower court's ruling denying further award of damages (apart from what was already given) to Sellner, who was arguing that when one of his creditors discovered that he was made the subject of an attachment, he was forced to sell sugar at a much lower rate, resulting in lesser income. The SC held that such damages were remote and speculative.