Philippine Steel Coating Corp. v. Quiñones

G.R. No. 194533, 19 April 2017

FACTS:

Respondent was producing buses while petitioner was selling primer-coated, long-span, rolled galvanized iron (G.I.) sheets. The petitioner offered Quiñones their product and the latter showed interest, but asked if the primer-coated sheets were compatible with its assembled buses. Petitioner expressly represented to respondent that the primer-coated G.I. sheets were compatible with the acrylic paint process used by the latter on his bus units. This representation was made in the face of respondent’s express concerns regarding incompatibility. Respondent bought the G.I. sheets and made them into buses. However, the paints peeled off and the customers complained. Respondent sued petitioner for damages on the basis of express warranty.

The RTC rendered a Decision in favor of Quiñones and ordered PhilSteel to pay damages. The RTC found that the assurance made by petitioner constituted an express warranty under Article 1546 of the Civil Code. The CA affirmed the ruling of the RTC in toto.

ISSUES:

1. Whether or not the “vague oral statements” made by the seller is a case of express warranty under Article 1546 of the Civil Code that may be invoked to warrant payment of damages.
2. Whether or not petitioner is considered an expert under art 1546.

RULING:

1. Yes. This Court agrees with the CA that this is a case of express warranty under Article 1546 of the Civil Code which 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 is to induce the buyer to purchase the same, and if the buyer purchases the thing relying thereon. No affirmation of the value of the thing, nor any statement purporting to be a statement of the seller’s opinion only, shall be construed as a warranty, unless the seller made such affirmation or statement as an expert and it was relied upon by the buyer.” 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.

The court resolves on the issue where petitioner argues that the purported warranties by mere “vague oral statements” cannot be invoked to warrant the payment of damages that— a warranty is not necessarily written. It may be oral as long as it is not given as a mere opinion or judgment. Rather, it is a positive affirmation of a fact that buyers rely upon, and that influences or induces them to purchase the product.

2. Yes. On the issue whether the petitioner was an expert on what they advised respondent, court resolves that— despite its claims to the contrary, petitioner was an expert in the eyes of the buyer Quinones. As the sales manager of PhilSteel, Angbengco made repeated assurances and affirmations and even invoked laboratory tests that showed compatibility. In the eyes of the buyer Quinones, PhilSteel -through its representative, Angbengco -was an expert whose word could be relied upon.”

*Case digest by Krishianne Louise C. Labiano, JD – 4, Andres Bonifacio College, SY 2019 – 2020

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