I was hospitalized after drinking a commercially sold juice that contained harmful substances — can I sue the manufacturer even though I never dealt with them directly?

No contract with the manufacturer is required

Article 2187 exists precisely because most consumers never deal directly with the company that made what they bought — they buy from a store, a distributor, or a vendor several steps removed from the manufacturer. Manufacturers and processors of foodstuffs, drinks, toilet articles and similar goods shall be liable for death or injuries caused by any noxious or harmful substances used, although no contractual relation exists between them and the consumers. The absence of a direct purchase relationship is expressly addressed and expressly does not defeat your claim.

What kind of harm the article covers

The liability attaches specifically to death or injuries caused by noxious or harmful substances used in the product — this covers a drink, food item, or similar good that was actually contaminated or otherwise contained something harmful, and that harmful content is what caused your hospitalization. Your situation, drinking a commercially sold juice that contained harmful substances and being hospitalized as a result, is the kind of harm this article is written to address.

Who can be held liable under this article

The article names manufacturers and processors of foodstuffs, drinks, toilet articles, and similar goods specifically. That means your claim under this article is properly directed at whoever actually made or processed the juice, not merely whoever sold it to you retail. A store or distributor may have separate obligations under other provisions or other laws, but Article 2187 itself speaks to the manufacturer's and processor's liability for what went into the product.

What you would still need to show

This article establishes that a manufacturer can be held liable without a direct contract, but you would still need to connect the harmful substance in the juice to the injury you suffered — that the drink actually contained something noxious or harmful, and that this is what caused your hospitalization. Keeping the product, its packaging, receipts, and your medical records is the kind of evidence that supports establishing that connection, since the article addresses who can be sued, not how the underlying facts get proven.

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.

• Coca-Cola Bottlers Phils., Inc. Vs.Ernani Guingona Meñez, G.R. No. 209906, November 22, 2017 — read the decision on LawPhil →

Related provisions

• Civil Code, Article 2187 — Liability of Food and Consumer-Goods Makers