Professional Documents
Culture Documents
RELEVANT FACTS
RATIO DECIDENDI
Macario Apostol, former President of Philippine Resources Development Corp. (PRDC),
submitted the highest bids for two purchase contracts with the Bureau of Prisons. Details of 1. Whether or not PRDC has material interest on the present case?
the contracts are as follows:
Yes. The materials purportedly belonging to the corporation have been assessed and
1. P450 per ton of 100 tons of Palawan Almagica evaluated and their price equivalent in terms of money have been determined; and that said
Value: P15,878.59 materials for whatever price they have been assessed, have been assigned by Apostol as
Paid: 691.10 tokens of payment of his private debts with the Bureau of Prisons.
Balance: P15,187.49
2. P88 per 1,000 board feet of 3 Million board feet of logs The court ruling on whether or not the price of the materials can be credited against
Value: P65,830.00 Apostol’s debt would have an effect on the claim of PRDC. Hence, is inescapable that the
Paid: 47,002.43 petitioner possesses a legal interest in the matter in litigation and that such interest is of an
Balance: P18,827.57 actual, material, direct and immediate nature as to entitle petitioner to intervene.
Total unpaid: P34,015.06 (15,187.49 + 18,827.57) 2. Whether or not the materials delivered by Apostol can be considered payment for
an existing debt?
Apostol failed to pay the balance, hence, the Bureau of Prisons demanded payment. Apostol
countered that he was already paid as he delivered certain materials (G.I. sheets, black Yes. Although the Court has not answered whether or not the price of the materials should
sheets, M.S. plates, round bars, G.I. pipes) of value to the Bureau. At this instance PRDC be credited as this case answers only the issue of the intervenor, the Court held that payment
sought to intervene as it claimed that it was the actual owner of the materials delivered by of the price need not be in money.
Apostol in his personal capacity to the Bureau of prisons. PRDC asserts that the sheets and
pipes were properties of the corporation to which Apostol was a former president, and The Government argues that "Price *** is always paid in terms of money and the supposed
Apostol used such materials to settle a personal obligation. payment being in kind, it is no payment at all," citing article 1458 of the new Civil Code.
However, the same article provides that the purchaser may pay "a price certain in money or
The Government (in behalf of the Bureau of Prisons) contends that the intervenor has no its equivalent," which means that payment of the price need not be in money.
legal interest in the matter in litigation, because the action brought is just for the collection
from the defendant Apostol of a sum of money, the unpaid balance of the purchase price of DISPOSITIVE
logs and almaciga bought by him from the Bureau of Prisons, whereas the intervenor seeks to
recover ownership and possession of G.I. sheets, black sheets, M.S. plates, round bars and The judgment under review is affirmed, without pronouncement as to costs.
G.I. pipes that it claims it owns.