Philippine Steel Coating, Corp. vs. Eduard Quinones (G.R. No. 194533) April 19, 2017
Facts: A complaint for damages was filed by respondent Quinones (owner of Amianan Motors) against petitioner PhilSteel. Richard Lopez, a sales engineer of PhilSteel, offered Quinones their new product: primer-coated, long-span, rolled galvanized iron (G.I.) sheets. The latter showed interest but asked if the primer-coated sheets were compatible with the Guilder acrylic paint process used by Amianan Motors in the finishing of its assembled buses. Uncertain, Lopez referred the query to his immediate superior, Ferdinand Angbengco, PhilSteel’s sales manager.
Angbengco assured Quinones that the quality of their new product was superior to that of the non-primer coated G.I. sheets being used by the latter in his business. He further guaranteed that a laboratory test had in fact been conducted by PhilSteel, and that the results proved that the two products were compatible.
However, Quinones received several complaints from customers who had bought bus units, claiming that the paint or finish used on the purchased vehicles was breaking and peeling off. Quinones sent a letter-complaint to PhilSteel claiming that the damage to the vehicles was attributable to the hidden defects of the primer-coated sheets and/or their incompatibility with the Guilder acrylic paint process used by the Amianan Motors. Because of the barrage of complaints, Quinones was forced to repair the damaged buses.
PhilSteel counters that that the breaking and peeling off of the paint was caused by the erroneous painting application done by Quinones.
The RTC rendered a Decision in favor of Quinones and ordered PhilSteel to pay damages. The trial court concluded that the paint blistering and peeling off were due to the incompatibility of the painting process with the primer-coated G.I. sheets. It also found out that the assurance made by Angbengco constituted an express warranty under Article 1546.
The CA affirmed the ruling of the RTC in toto.
- Were the oral statements made by Angbengco a case of express warranty under Article 1546 of the Civil Code that may be invoked to warrant payment of damages?
- Is non-payment of price justified on allegations of breach of warranty?
- Yes. Article 1546 of the Civil Code provides that any affirmation of fact or any promise by the seller relating to the thing is an express warranty if the natural tendency of such affirmation or promise if to induce the buyer to purchase the same, and if the buyer purchases the thing relying thereon. As held in Carrascoso, Jr. vs. CA, the following requisites must be established in order to prove that there is an express warranty in a contract of sale: (1) the express warranty must be an affirmation of fact or any promise by the seller relating to the subject matter of the sale; (2) the natural effect of the affirmation or promise is to induce the buyer to purchase the thing; and (3) the buyer purchases the thing relying on that affirmation or promise. Here, the oral statements of Angbengco created an express warranty. hey were positive affirmations of fact that the buyer relied on, and that induced him to buy petitioner’s primer-coated G.I. sheets. Seller is expert in the eyes of the buyer.
- Yes, the non-payment of the unpaid purchase price was justified since a breach of warranty was proven. Quinones has opted for a reduction in price or non-payment of the unpaid balance of the purchase price. According to Article 1599, Civil Code, recoupment refers to the reduction of extinction of the price of the same item, unit, transaction or contract upon which a plaintiff’s claim is founded.