San Miguel Foods, Inc. v. Spouses Ramon and Ma. Nelia Fabie, and Fresh Link, Inc.

Case Title:

G.R. No.: 234849

Date: June 30, 2024

Ponente: Justice Hernando

Facts:

  • Fresh Link, Inc., owned by Spouses Ramon and Nelia Fabie, entered into a Complementary Distributorship Agreement with San Miguel Foods, Inc. (SMFI) in 1992, which was renewed yearly.
  • In April 1999, the agreement was renewed again to expire on March 31, 2000.
  • On June 4, 1999, SMFI ceased delivery of products on credit to Fresh Link.
  • Fresh Link filed a complaint against SMFI for breach of contract and damages, alleging SMFI unilaterally terminated the agreement.
  • SMFI claimed Fresh Link had unpaid accounts and its letter of credit had expired.
  • The RTC ruled in favor of Fresh Link and awarded damages. The Court of Appeals affirmed with modifications.

Issues:

  1. Whether SMFI is entitled to its counterclaims
  2. Whether SMFI unilaterally terminated the agreement with Fresh Link
  3. Whether respondents are entitled to damages

Ruling:

  1. SMFI is not entitled to its counterclaims. The documents submitted were mere photocopies, inadmissible under the best evidence rule.
  2. Respondents failed to prove by preponderance of evidence that SMFI unilaterally terminated the agreement. Evidence showed SMFI only denied credit purchases, not terminated the agreement entirely.
  3. Respondents are not entitled to damages. They failed to sufficiently prove SMFI’s alleged breaches of contract beyond Nelia Fabie’s testimony and complaint letters.

The Supreme Court reversed the CA decision and dismissed Fresh Link’s complaint for lack of merit.

Dispositive Portion:
The Petition is GRANTED. The May 18, 2017 Decision and October 18, 2017 Resolution of the Court of Appeals are REVERSED and SET ASIDE. The Complaint filed by respondents is DISMISSED for lack of merit.

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