G.R. No. L-26719 February 27, 1970
THE PHILIPPINE AMERICAN LIFE INSURANCE COMPANY, petitioner, vs. HONORATO R. SANTAMARIA and COURT OF APPEALS (First Division), respondents.

FACTS

Petitioner Philippine American Life Insurance Company engaged respondent Honorato R. Santamaria, a contractor, to conduct a topographic survey of its 45-hectare lot in Quezon City. Respondent’s written proposal, dated September 3, 1952, offered to conduct both a topographic and a subdivision survey. Petitioner accepted only the topographic survey portion. Respondent clarified the terms on September 23, 1952, stating the survey would be “in accordance with a 10-meter cross-sectioning and profile survey and a contour interval of 25 centimeters,” and he would furnish a map at scale 1 to 100. Petitioner agreed. The survey was conducted from October 3 to November 15, 1952, and petitioner paid the agreed fee of P3,600.00. Petitioner later sued for damages, claiming respondent’s topographic map was defective, causing additional expenses for resurvey, road grading changes, building design alterations, a reduction in the shopping center area, and project delays. Respondent defended that his contract did not require him to determine exact boundaries, as that task was part of the rejected subdivision survey offer. He also claimed petitioner’s representatives instructed him to proceed without a precise boundary plan due to time constraints, with any discrepancies to be remedied later. The trial court ruled for petitioner, but the Court of Appeals reversed, dismissing the complaint.

ISSUE

Whether respondent Santamaria is liable for damages under Article 1715 of the Civil Code for alleged defects in the topographic survey work.

RULING

No. The Supreme Court affirmed the decision of the Court of Appeals. The Court held that respondent Santamaria was neither at fault nor remiss in performing his duty under the contract. The contract, as accepted by petitioner, was limited to a topographic survey only. The obligation to relocate boundary monuments was part of the subdivision survey, which petitioner had rejected. Furthermore, the topographic survey commenced before petitioner had even finalized the purchase of the land from the Philippine Homesite and Housing Corporation. Given these factual circumstances, respondent executed the work in accordance with the agreed terms. The Court found that the Court of Appeals had meticulously analyzed the facts and correctly concluded no negligence or incompetence existed. Petitioner’s interpretation of Article 1715 of the Civil Code, as imposing an absolute duty of perfectibility, was rejected as unreasonable under the circumstances.