Several obligations; one cause of action

In contracts providing several obligations, each obligation may give rise to a single and independent cause of action. But if several obligations have matured, or if the entire contract is breached at the time of the filing of the complaint, all obligations are integrated into one cause of action. Hence, the claim arising from such cause of action that is not included in the complaint is barred forever. The Supreme Court's explanation in Blossom and Company, Inc. v. Manila Gas Corporation,(55 Phil. 226 [1930]) citing US jurisprudence on the matter, is instructive, viz:
34 Corpus Juris, p. 839, it is said:
As a general rule[,] a contract to do several things at several times in its nature, so as to authorize successive actions; and a judgment recovered for a single breach of a continuing contract or covenant is no bar to a suit for a subsequent breach thereof. But where the covenant or contract is entire, and the breach total, there can be only one action, and [the] plaintiff must therein recover all his damages.
In the case of Rhoelm v. Horst, 178 U. U., 1; 44 Law. ed., 953, that court said:
An unqualified and positive refusal to perform a contract, though the performance thereof is not yet due, may, if the renunciation goes to the whole contract, be treated as a complete breach which will entitle the injured party to bring his action at once. 

Popular Posts