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Case Digest - G.R. No. 10918 - Fressel vs. Mariano Uy Chaco Sons and Co

In the case of Fressel vs. Mariano Uy Chaco Sons and Co., the court ruled that the defendant is not liable for materials purchased by an independent contractor, E. Merritt, who was hired to construct a building. The court found that Merritt acted as an independent contractor rather than an agent of the defendant, leading to the dismissal of the plaintiffs' complaint. The ruling affirms that without a mechanics' lien statute, a building owner is not responsible for materials acquired by an independent contractor.

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48 views2 pages

Case Digest - G.R. No. 10918 - Fressel vs. Mariano Uy Chaco Sons and Co

In the case of Fressel vs. Mariano Uy Chaco Sons and Co., the court ruled that the defendant is not liable for materials purchased by an independent contractor, E. Merritt, who was hired to construct a building. The court found that Merritt acted as an independent contractor rather than an agent of the defendant, leading to the dismissal of the plaintiffs' complaint. The ruling affirms that without a mechanics' lien statute, a building owner is not responsible for materials acquired by an independent contractor.

Uploaded by

Eric Seno
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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8/30/24, 9:17 PM Case Digest: G.R. No. 10918 - Fressel vs. Mariano Uy Chaco Sons and Co.

Title
Fressel vs. Mariano Uy Chaco Sons and Co.

Case Decision Date


G.R. No. 10918 Mar 4, 1916

In a case involving the construction of a building, the court rules that the owner
is not liable for the payment of materials purchased by an independent
contractor, affirming the dismissal of the case.

Case Digest (G.R. No. 10918)


Comprehensive

Facts:
Plaintiffs-appellants: William Fressel and others.
Defendant-appellee: Mariano Uy Chaco Sons & Company.
Dispute: Construction contract from late 1913.
Contract detail: Defendant hired E. Merritt to construct a building at Calle Rosario
and Plaza de Padre Moraga, Manila.
Condition: Defendant could take possession of the unfinished building and
materials before completion.
Timeline: August 1914 - Plaintiffs supplied materials worth P1,381.21 to Merritt, with
payment due on September 1, 1914.
August 28, 1914: Defendant took control of the incomplete building and materials.
Issue: Neither Merritt nor the defendant paid for the materials.
Plaintiffs' claim: Merritt acted as the defendant's agent in procuring materials,
obligating the defendant to pay.
Lower court ruling: Complaint dismissed for failing to state a valid cause of action.

Issue:
1. Was Merritt acting as an independent contractor or an agent of the defendant in
acquiring materials from the plaintiffs?
2. Is the defendant liable for the payment of materials purchased by Merritt under the
construction contract?

Ruling:

https://jur.ph/jurisprudence/digest/fressel-v-mariano-uy-chaco-sons-co#_ 1/2
8/30/24, 9:17 PM Case Digest: G.R. No. 10918 - Fressel vs. Mariano Uy Chaco Sons and Co.

1. Merritt was acting as an independent contractor.


2. The defendant is not liable for the payment of materials purchased by Merritt.

Ratio:
Interpretation of Contractual Relationship: Merritt was authorized to perform the
work according to his own methods, subject only to the final result.
Independent Contractor Status: Merritt was not under the defendant's control,
except for the final outcome, ensuring his classification as an independent
contractor.
Possession Clause: Defendant's right to take possession of the unfinished building
and materials did not alter Merritt's status.
Principal-Agent Relationship: Complaint did not establish Merritt as an agent of the
defendant.
Legal Precedent: In the absence of a mechanics' lien statute, a building owner is not
liable for materials purchased by an independent contractor.
Conclusion: Allegations in the complaint were insufficient for a cause of action
against the defendant, leading to the affirmation of the lower court's judgment with
costs against the appellants.

Unlock Full Case Digest

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