Facts:

The case involves C & C Commercial Corporation as the plaintiff-appellee and the National Waterworks and Sewerage Authority (NAWASA) as the defendant-appellant. The events leading to the case began on July 7, 1965, when C & C Commercial Corporation filed a petition for declaratory relief in the Court of First Instance of Manila. The petition sought a judicial interpretation of the term "practicable" as used in Republic Act No. 912, which mandates the use of locally produced materials in government construction projects. The case evolved into an action for prohibition with a preliminary injunction after C & C alleged that NAWASA was negotiating to purchase imported centrifugally cast iron pipes for the San Pablo Waterworks System, thereby excluding their locally available asbestos cement pressure pipes.

The NAWASA had called for bids for various waterworks projects, including the Davao Metropolitan Waterworks System and the Iloilo Waterworks System, spe...

Facts:

1. Background of the Case:

   • The case involves the National Waterworks and Sewerage Authority (NAWASA) and C & C Commercial Corporation.
   • The main issue is whether NAWASA violated Republic Act No. 912 by specifying imported steel pipes in its call for bids for waterworks projects in Manila, Davao, and Iloilo, instead of using locally produced materials.
   • Republic Act No. 912 mandates the use of Philippine-made materials in government construction or repair projects if they are available, practicable, and usable.

2. San Pablo Waterworks System:

   • NAWASA was accused of negotiating for the direct purchase of centrifugally cast iron pipes (CCI) for the San Pablo Waterworks System, allegedly violating Republic Act No. 912.
   • C & C Commercial Corporation claimed it could supply asbestos cement pressure pipes, which were cheaper and locally available.
   • The court dismissed the complaint regarding the San Pablo project, and the decision became final.

3. Davao Metropolitan Waterworks:

   • NAWASA called for bids for 24-inch steel pipes for the Davao project.
   • C & C Commercial Corporation filed a supplemental complaint, alleging that NAWASA violated Republic Act No. 912 by specifying steel pipes instead of locally available asbestos cement pressure pipes.
   • The court issued a preliminary injunction restraining NAWASA from proceeding with the award.

4. Iloilo Waterworks System:

   • NAWASA called for bids for 18-inch steel pipes for the Iloilo project in 1962.
   • C & C Commercial Corporation lost the bid but later filed a supplemental complaint, alleging a violation of Republic Act No. 912.
   • The court admitted the complaint and issued a restraining order.

5. Manila and Suburbs Waterworks System:

   • NAWASA advertised for bids for 30 to 42-inch steel pipes for the Manila project.
   • C & C Commercial Corporation filed a third supplemental complaint, alleging the same violation of Republic Act No. 912.
   • The court issued a preliminary injunction restraining NAWASA from holding the bidding.

6. NAWASA's Defense:

   • NAWASA argued that C & C Commercial Corporation could not produce asbestos cement pressure pipes larger than 12 inches in diameter at the time of the bids.
   • NAWASA also contended that Republic Act No. 912 did not apply to it, as it was not a municipal corporation or agency of the State.

7. Lower Court Decision:

   • The Court of First Instance ruled in favor of C & C Commercial Corporation, finding that NAWASA violated Republic Act No. 912.
   • The court issued permanent injunctions and ordered the reappraisal of bids for the Davao, Iloilo, and Manila projects.

Issue:

1. Whether NAWASA, as a public corporation, is included within the term "Government" under Republic Act No. 912.
2. Whether NAWASA violated Republic Act No. 912 by specifying steel pipes in its call for bids instead of locally produced materials.
3. Whether the lower court erred in issuing permanent injunctions and ordering the reappraisal of bids.

Ruling:

The Supreme Court reversed the decision of the lower court. It held that:

1. NAWASA is included within the term "Government" under Republic Act No. 912, as the law aims to promote the use of locally produced materials in government projects.
2. NAWASA did not violate Republic Act No. 912 because locally produced asbestos cement pressure pipes larger than 12 inches in diameter were not available at the time of the bids.
3. The lower court erred in issuing permanent injunctions and ordering the reappraisal of bids, as C & C Commercial Corporation failed to prove that its products were available, practicable, and usable for the projects in question.

Ratio:

1. Interpretation of "Government":

   • The term "Government" in Republic Act No. 912 should be construed broadly to include government-owned or controlled corporations like NAWASA, as the law aims to promote the use of locally produced materials in government projects.

2. Availability of Locally Produced Materials:

   • For a material to be considered "available" under Republic Act No. 912, it must be physically present and ready for use at the time of the bidding.
   • C & C Commercial Corporation could not produce asbestos cement pressure pipes larger than 12 inches in diameter at the time of the bids, and thus, the preference under the law did not apply.

3. Strict Compliance with Statutory Requirements:

   • Statutes granting advantages to private persons, such as Republic Act No. 912, must be strictly construed.
   • C & C Commercial Corporation failed to comply with the requirement of obtaining a certification from the Director of Public Works before claiming any preference under the law.

4. Mootness of the Manila Project:

   • The issue regarding the Manila project became moot due to the passage of Republic Act No. 4858, which authorized the President to allow the procurement of supplies necessary for the project as an exception to Republic Act No. 912.

The Supreme Court set aside the lower court's decision, dissolved the injunctions, and ruled in favor of NAWASA, with costs against C & C Commercial Corporation.