Short answer. No. Article 1246 of the Civil Code states that when an obligation involves a generic thing whose quality is unspecified, the creditor cannot demand a thing of superior quality. You are entitled to rice of a medium or average grade, based on the purpose of the obligation and surrounding circumstances.
What the law says
the creditor cannot demand a thing of superior quality. Neither can the debtor deliver a thing of inferior quality. The purpose of the obligation and other circumstances shall be taken into consideration.
Civil Code, Article 1246 — Quality of a Generic Thing. Read the full provision →
Generic obligations and the quality rule
Article 1246 applies to generic or indeterminate obligations — those where the contract identifies only the kind of thing, not a specific item. 'Rice' without further description is a classic generic obligation. The article sets a middle-ground rule: the creditor cannot demand superior quality, and the debtor cannot deliver inferior quality. Neither party gets to exploit the silence in the contract. The rule pushes both sides toward the middle: average or medium quality for that type of good.
What 'superior' and 'inferior' mean here
The standard is relative to the range of quality available in the market for that commodity. Superior quality means a grade above the average — premium, special, or top-tier rice. Inferior quality means substandard or low-grade rice that no reasonable buyer would accept as adequate. A seller who delivers the cheapest, worst-quality rice available and calls it compliance is in breach. But a buyer who insists on the most expensive, finest variety when the contract says nothing is equally overreaching.
Purpose and circumstances as the deciding factor
Article 1246 does not stop at 'medium quality.' It adds that the purpose of the obligation and other circumstances must be taken into consideration. This contextual element matters. If the rice was being purchased for resale in a premium restaurant supply chain, the surrounding circumstances may push toward a higher quality standard even if the contract is silent. If it was for institutional bulk feeding, a lower standard may be appropriate. Context fills the gap that the contract's silence created — but neither extreme can be demanded without contractual basis.
What to do if there is a dispute
If the seller delivers rice and you believe it is below the quality the contract implied, the question is whether it falls below the standard that the purpose and circumstances require. Gather evidence: samples, market comparisons, the intended use as shown in communications or invoices, and any trade custom about grade expectations for that type of transaction. If the seller refuses to replace the delivery with appropriate quality, you may have a claim for breach of the obligation. A lawyer can assess whether the quality delivered meets the Article 1246 standard given your specific contract and context.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Aurora Fe B. Camacho vs. Court of Appeals, et al, G.R. No. 127520, February 9, 2007 — read the decision on LawPhil →