Case Digest (G.R. No. 162525)
Facts:
The case involves a petition filed by Asean Pacific Planners (APP), Asean Pacific Planners Construction and Development Corporation (APPCDC), and Cesar Goco against the City of Urdaneta and several individuals, including Ceferino J. Capalad and Waldo C. Del Castillo. The events leading to this petition began when Waldo C. Del Castillo, acting as a taxpayer, filed a complaint for annulment of contracts against the City of Urdaneta and its then Mayor Rodolfo E. Parayno, who had entered into five contracts for the design, construction, and management of a four-storey twin cinema commercial center and hotel. The total expenditure for this project was approximately P250 million, funded by a loan from the Philippine National Bank (PNB). Del Castillo alleged that the contractor was paid P95 million for minimal work and claimed that the contracts were void as they involved public land designated for a public elementary school. He further contended that the contracts were awarded sole...
Case Digest (G.R. No. 162525)
Facts:
- This case involves a petition for certiorari seeking to set aside the Court of Appeals’ Resolutions dated April 15, 2003, and February 4, 2004, in CA-G.R. SP No. 76170.
- The petitioners are ASEAN PACIFIC PLANNERS (APP) and APP CONSTRUCTION AND DEVELOPMENT CORPORATION (APPCDC), represented by Cesar Goco and Ronilo Goco, respectively.
- The respondents include the City of Urdaneta, Ceferino J. Capalad, Waldo C. Del Castillo, Norberto M. Del Prado, Jesus A. Ordono, and Aquilino Maguisa.
Case Background
- The dispute originated from a Complaint for annulment of contracts with a prayer for a preliminary prohibitory injunction and a temporary restraining order.
- Taxpayer Waldo C. Del Castillo, acting in his capacity as such, contended that then City Mayor Rodolfo E. Parayno had entered into five contracts for the preliminary design, construction, and management of a four‐storey twin cinema commercial center and hotel.
- The alleged contracts involved a massive public fund expenditure of P250 million, funded by a loan from the Philippine National Bank (PNB), with an alleged disbursement of P95 million for minimal work.
- Del Castillo asserted that the contracts were void on two grounds:
- The object of the contracts was allegedly outside the commerce of men since it involved public domain land devoted to a public elementary school.
- The contracts were purportedly tainted by irregularity as they were awarded solely to the Goco family.
Underlying Dispute
- In their Answer, APP and APPCDC maintained that the contracts were valid.
- The City of Urdaneta, represented by Mayor Amadeo R. Perez, joined in the defense, asserting that the contracts were properly executed with the requisite authority of the Sangguniang Panlungsod.
- Respondent Ceferino J. Capalad, through his counsel, filed an Answer with a compulsory counterclaim and a motion to dismiss on the ground of lack of legal standing of Del Castillo.
- Additional taxpayer complainants (Del Castillo, Del Prado, Ordono, and Maguisa) joined the case by filing a Complaint-in-Intervention that echoed Del Castillo’s allegations.
- A controversy arose when the Lazaro Law Firm entered its appearance as counsel for Urdaneta City. The firm sought, inter alia, to withdraw the city’s earlier Answer, to drop the city as a defendant, and to admit the city’s complaint—alleging that the city’s initial legal representation was inadequate.
- The Regional Trial Court (RTC) of Urdaneta City, Branch 45, issued orders (dated September 11, 2002, and February 14, 2003) addressing these appearances and representations, including the consolidation of complaints and the expunging of pleadings filed by opposing counsel.
- Aggrieved by these developments, APP and APPCDC filed a petition for certiorari with the Court of Appeals. Their petition was summarily dismissed on procedural technicalities—including defective verification and certification of non-forum shopping and the submission of photocopies instead of certified true copies.
- Despite the submission of additional proof of substantial compliance in their motion for reconsideration, the Court of Appeals reaffirmed its dismissal in a subsequent Resolution dated February 4, 2004.
Procedural History and Developments
Issue:
- Whether the Court of Appeals erred in dismissing the petition on mere technicalities—specifically the alleged defects in the verification and certification of non-forum shopping—despite petitioners’ subsequent submission of the required proof of authority and certified documents.
Procedural Grounds
- Whether the RTC committed a grave abuse of discretion by:
- Entertaining the suits filed by the taxpayer complainants (Del Castillo, Del Prado, Ordono, and Maguisa) despite disputes regarding their legal standing.
- Allowing, contrary to statutory and jurisprudential mandates, a private law firm (the Lazaro Law Firm) to represent Urdaneta City instead of the duly designated City Prosecutor or legal officer.
- Permitting respondents such as Capalad and Urdaneta City to switch sides—from being defendants to becoming complainants—through the withdrawal of their answers and the admission of new complaints.
- Allowing a change of counsel for Capalad (from Atty. Oscar C. Sahagun to Atty. Jorito C. Peralta) without complying with the well-settled rules on conflicting interests and proper representation.
Questions on the Intervention and Representation
- Whether Urdaneta City is estopped from reversing its prior judicial admissions (in its Answer and pre-trial brief) that the contracts at issue were valid, despite the contrasting claims brought forward by the taxpayer complainants regarding the misuse or misallocation of public funds.
Substantive Contractual Validity
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)