GR L 3488; (August, 1907) (Digest)
G.R. No. L‑3488
Facts
– The sailing vessel Alta was wrecked off Cavite on 26 September 1905.
– The owners contracted with the plaintiffs, C. S. Robinson & Co., in writing (1 Nov 1905) to raise the ship, place her in Cavite and make her fit to sail to Hong Kong (or “other port”), subject to a Lloyd’s survey, for a sum of ₱15,000.
– The contract expressly stipulated that no payment would be due if the work was not successful.
– The plaintiffs raised the ship, towed her to Cavite and began examinations in the dry‑dock; work ceased on 20 January 1906. They received only ₱3,000 on 30 Dec 1905.
– Plaintiffs sued for the reasonable value of their services (≈ ₱15,000). The trial court awarded them ₱9,760; the defendants appealed.
Issue
Whether a salvage contract that is contingent upon success is binding on the salvors, or may be set aside so that the salvors recover on a quantum‑meruit basis despite the contractual stipulation that no payment is due if the salvage fails.
Ruling
The Court held that a contract, even if conditioned on the success of the salvage, is binding and enforceable absent fraud, mistake, coercion, or other inequitable circumstances. The parties knowingly entered into the agreement; the contingency does not void the obligation to pay the stipulated sum if the work is successful. Consequently, the trial‑court judgment in favor of the plaintiffs was reversed, the defendants were absolved of liability, and no costs were awarded to either party.
