Short answer. Generally no liability for the loss, but you get your money back. Article 1174 excuses events that could not be foreseen or were inevitable. The catch is that this only saves a supplier who owed a specific identified thing — a generic order of goods must still be filled.
What the law says
Except in cases expressly specified by the law, or when it is otherwise declared by stipulation, or when the nature of the obligation requires the assumption of risk, no person shall be responsible for those events which could not be foreseen, or which, though foreseen, were inevitable.
Civil Code, Article 1174 — Fortuitous Events. Read the full provision →
What the law says
In an obligation to deliver a generic thing, the loss or destruction of anything of the same kind does not extinguish the obligation.
Civil Code, Article 1263 — Loss of a Generic Thing (Genus Nunquam Perit). Read the full provision →
The excuse, with its exceptions built in
Article 1174 states the rule this way: Except in cases expressly specified by the law, or when it is otherwise declared by stipulation, or when the nature of the obligation requires the assumption of risk, no person shall be responsible for those events which could not be foreseen, or which, though foreseen, were inevitable. A typhoon is the standard example. But the exceptions are not decoration: a contract term allocating the risk of loss to the supplier, or a law imposing liability, displaces the excuse entirely. Read the supply contract before conceding anything.
Specific thing or generic goods?
This is the question that decides most of these disputes. Article 1262 extinguishes an obligation to deliver a determinate thing if it is lost or destroyed without the debtor's fault and before he has incurred in delay. Article 1263 says the opposite for generic obligations: In an obligation to deliver a generic thing, the loss or destruction of anything of the same kind does not extinguish the obligation. So if you ordered a particular identified machine that was set aside for you and it was washed away, the obligation dies with it. If you ordered fifty sacks of cement, the supplier's flooded stock is his problem — cement still exists.
Delay destroys the excuse
Timing matters as much as the storm. Article 1262 protects the debtor only where the loss happened before he incurred in delay, and Article 1165 makes an obligor who delays, or who promised the same thing to two or more persons, responsible for any fortuitous event until delivery is effected. A supplier already overdue when the typhoon arrived therefore cannot shelter behind it. So the first thing to establish is the agreed delivery date and whether a demand had been made — the same dated correspondence that would matter in any other breach.
Your money, and who bore the risk
Being excused from delivering is not the same as keeping the price. Where the obligation is extinguished, the supplier has no cause to retain what you paid for goods you will never receive, and a refund is the ordinary consequence. On risk, Article 1504 provides that unless otherwise agreed the goods remain at the seller's risk until ownership in them is transferred to the buyer. So ask three questions: had ownership passed, was the order specific or generic, and was delivery already overdue? The answers, plus the contract's own force majeure clause, settle whether this loss is yours or the supplier's.
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.
- Philippine Communications Satellite Corporation vs. Globe Telecom Inc., et al, G.R. No. 147324, May 25, 2004 — read the decision on LawPhil →
- Roberto C. Sicam, et al. vs. Lullu V. Jorge, et al, G.R. No. 159617, August 8, 2007 — read the decision on LawPhil →
- Philippine Realty and Holding Corp. vs. Ley Const. and Dev. Corp./Ley Cons. and Dev. Corp. vs. Philippine Realty and Holding Corp, G.R. No. 165548 / G.R. No. 167879, June 13, 2011 — read the decision on LawPhil →
- Filonila O. Cruz vs. Hon. Celso D. Gangan, et al, G.R. No. 143403, January 22, 2003 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1174 — Fortuitous Events
- Civil Code, Article 1262 — Loss of a Determinate Thing
- Civil Code, Article 1263 — Loss of a Generic Thing (Genus Nunquam Perit)
- Civil Code, Article 1165 — Remedies for Failure to Deliver
- Civil Code, Article 1504 — Risk of Loss Follows Ownership