Executive Summary: Key Legal and Evidentiary Issues

• Germain St-Amour claimed $1,491.40 from Emmanuel Coulombe for branch sorting and preparation services connected to essential oil production.
• At issue was whether a verbal agreement had been reached on a rate of $25 per tonne for the sorting operation, which Coulombe disputed.
• Under Article 2100 of the Civil Code of Québec, a service provider must inform the client of the price before performing work — an obligation St-Amour failed to meet.
• No agreed price having been established, the court was required to determine fair value under Article 2106 C.c.Q.
• Testimonial evidence from Renaud St-Amour was insufficient to establish $25 per tonne as the prevailing industry rate, as no supporting invoices or contemporary documents were produced.
• Court costs were denied to the claimant because only a negligible fraction of the original claim was granted.

Facts of the case

On June 11, 2026, the Court of Québec (Small Claims Division) in the District of Labelle issued judgment in the matter of St-Amour c. Coulombe (2026 QCCQ 2691), presided over by the Honourable Stéphane D. Tremblay, J.C.Q. Germain St-Amour brought a claim against Emmanuel Coulombe seeking $1,491.40 for forestry services rendered. The parties had an admitted verbal agreement for the use of a delimbing machine to debranch trees at a rate of $8 per tonne, which was performed and paid without dispute. St-Amour alleged a further verbal agreement covered the preparation and sorting of 45 tonnes of branches intended for essential oil production, billed at $25 per tonne plus applicable taxes — a charge Coulombe refused to pay. While Coulombe acknowledged he expected to be billed for the sorting work, he disputed that any rate of $25 per tonne had ever been agreed upon and considered the amount excessive given the time the operation required.

Contractual and statutory provisions at issue

Article 2100 of the Civil Code of Québec requires a service provider to act in the client's best interests with prudence and diligence, an obligation that expressly includes informing the client of the price of services before work is carried out. Where no price is fixed by the contract, Article 2106 C.c.Q. permits the court to set a price based on industry usage, applicable law, or the value of the work actually performed.

Reasoning and analysis

The court found that St-Amour had not informed Coulombe of the $25 per tonne rate prior to performing the sorting work and therefore could not unilaterally impose that rate on his contracting party. Turning to Article 2106, the court noted that Coulombe himself acknowledged it was customary for sorting to be billed, establishing that the service carried recognisable value. However, the testimony of Renaud St-Amour — responsible for forestry operations for the claimant — that $25 per tonne was the standard rate was unsupported by any contemporary invoices or documents demonstrating that rate was actually charged to the majority of clients. The court accordingly declined to accept that figure as established industry usage. Witness testimony further indicated that the sorting operation does not substantially extend the time required to complete the delimbing work, as the two operations are performed nearly simultaneously once the machinery is already mobilised. On that basis, the court determined that $4 per tonne represented the fair and reasonable value of the sorting work performed.

Ruling and overall outcome

The claim was granted in part. The court condemned Emmanuel Coulombe to pay Germain St-Amour the sum of $206.96 — calculated at $4 per tonne for 45 tonnes ($180.00) plus applicable taxes — together with interest at the legal rate and the additional indemnity under Article 1619 C.c.Q., running from the date of formal demand on March 21, 2023. That date was established from the demand letter of March 13, 2023, which granted a seven-day period to pay. No court costs were awarded to St-Amour, as only a negligible portion of the original $1,491.40 claim was allowed.