ARCO PULP AND PAPER CO., INC. and CANDIDA A.

SANTOS,
Petitioners, vs. DAN T. LIM, doing business under the name and style
of QUALITY PAPERS & PLASTIC PRODUCTS ENTERPRISES,
Respondent.
G.R. No. 206806 June 25, 2014 Leonen, J.

The parties allegedly agreed that Arco Pulp and Paper would either pay Dan
T. Lim the value of the raw materials or deliver to him their finished products
of equivalent value.

Issue: Whether or not the obligation is alternative. Whether or not the

obligation had already been converted to a simple obligation.

Ruling: Yes. By agreement, petitioner Arco Pulp and Paper, as the debtor,
had the option to either (1) pay the price or(2) deliver the finished products
of equivalent value to respondent.
The appellate court, therefore, correctly identified the obligation between the
parties as an alternative obligation, whereby petitioner Arco Pulp and Paper,
after receiving the raw materials from respondent, would either pay him the
price of the raw materials or, in the alternative, deliver to him the finished
products of equivalent value.
When petitioner Arco Pulp and Paper tendered a check to respondent in
partial payment for the scrap papers, they exercised their option to pay the
price. Respondent’s receipt of the check and his subsequent act of depositing
it constituted his notice of petitioner Arco Pulp and Paper’s option to pay.
This choice was also shown by the terms of the memorandum of agreement,
which was executed on the same day. The memorandum declared in clear
terms that the delivery of petitioner Arco Pulp and Paper’s finished products
would be to a third person, thereby extinguishing the option to deliver the
finished products of equivalent value to respondent.

SPOUSES RODOLFO BEROT AND LILIA BEROT, Peitioners v. FELIPE

C. SIAPNO, Respondent.
G.R. No. 188944 July 9, 2014 Sereno, C.J.

Issue : Whether the loan obligation contracted by petitioners is joint or

solidary.

Ruling: Joint. Art. 1207. The concurrence of two or more creditors or of two
or more debtors in one and the same obligation does not imply that each
one of the former has a right to demand, or that each one of the latter is
bound to render, entire compliance with the prestations. There is a
solidary liability only when the obligation expressly so states, or
when the law or the nature of the obligation requires solidarity.

Ruks Konsult and Construction vs. Adworld Sign and Advertising

Corporation and Transworld Media Ads
G.R. No. 204866 January 21, 2015 J. Perlas-Bernabe

Issue : Whether petitioner is jointly or solidarily liable with Transworld.

Ruling: Soliday. As joint tortfeasors, therefore, they are solidarily liable to

Adworld. Verily, "[j]oint tortfeasors are those who command, instigate,
promote, encourage, advise, countenance, cooperate in, aid or abet the
commission of a tort, or approve of it after it is done, if done for their
benefit. They are also referred to as those who act together in committing
wrong or whose acts, if independent of each other, unite in causing a single
injury. Under Article 219429 of the Civil Code, joint tortfeasors are solidarily
liable for the resulting damage. In other words, joint tortfeasors are each
liable as principals, to the same extent and in the same manner as if they
had performed the wrongful act themselves."