OPTIMUM MOTOR CENTER CORPORATION v. ANNIE TAN

FACTS:

Respondent Annie Tan, doing business under the name "AJ & T Trading," filed a Complaint for recovery of possession against Optimum Motor Center Corporation (Optimum) and Cesar Peña with the Regional Trial Court (RTC) of Manila. Respondent is the registered owner of an Isuzu cargo truck that she brought to Optimum for body repair and painting. Respondent verbally contracted with Peña for the repair work, which was agreed to be completed within 30 days. However, when respondent went to claim her truck, she was informed that the repair was not yet finished. On subsequent visits, she noticed that the truck had been scraped off and certain parts were missing. Eventually, she found her truck abandoned and unrepaired at Optimum's compound. Respondent filed a complaint for the recovery of possession or payment of the value of the truck, along with other damages. The trial court ruled in favor of respondent, ordering Optimum to surrender the truck or pay the value, along with other damages. Optimum filed a Notice of Appeal, while respondent moved for reconsideration seeking additional damages.

ISSUES:

  1. Whether the repairs on the truck were completed within the agreed 30-day period.

RULING:

  1. The Supreme Court ruled in favor of the respondent. The repairs on the truck were not completed within the agreed 30-day period. The Court cited the testimonies of independent witnesses who observed the condition of the truck, which supported respondent's claim. The Court held Optimum liable for damages for its failure to fulfill its contractual obligations on time, in accordance with Article 1170 of the Civil Code.

PRINCIPLES:

  • Non-compliance with contractual obligations within the agreed time frame may result in liability for damages under Article 1170 of the Civil Code.