GR 1171; (September, 1903) (Digest)

G.R. No. L-1171, September 9, 1903
ROBERTO AND JOSE T. FIGUERAS, plaintiffs-appellees, vs. MANUEL VY-TIEPCO, defendant-appellant.

FACTS:
On January 29, 1900, the plaintiffs, Roberto and Jose T. Figueras, entered into a written contract with the defendant, Manuel Vy-Tiepco, for the construction of a house on Rosario Street, Iloilo. The contract stipulated that the house was to be built in accordance with specific plans and completed within four months. The plaintiffs filed an action in the Court of First Instance of Iloilo, alleging that the defendant failed to complete the construction in conformity with the contract, leaving numerous items unfinished, which diminished the value of the work by $1,544. They demanded that the defendant complete the work or compensate them for the deficiency. The defendant, in his answer, denied the allegations, claiming he had substantially performed the contract except for two arches omitted upon the plaintiffs’ instruction, and that the plaintiffs had paid the balance due without complaint. He further contended that the plans presented by the plaintiffs in court were not the original plans referenced in the contract. The trial court ruled in favor of the plaintiffs, relying on the copy of the plan they presented. The defendant appealed, assigning errors of law.

ISSUE:
Whether the trial court erred in rendering judgment based on a copy of the construction plan that was not proven to be the original plan forming part of the contract between the parties.

RULING:
Yes. The Supreme Court reversed the judgment of the trial court. The Court held that the plan presented by the plaintiffs as evidence was not established to be the original plan referred to in the written contract. The defendant had properly objected to its admission. Without the original plan, it was impossible to determine whether there had been a breach of contract or whether the defendant had failed to complete the specified work. The trial court therefore erred in basing its decision on an unauthenticated document. The Supreme Court set aside the judgment and remanded the case to the trial court for a new trial. Costs of the appeal were taxed against the plaintiffs-appellees.