G.R. No. 212081 - Department of Environment and Natural Resources vs. United Planners Consultants, Inc.

On July 26, 1993, the Department of Environment and Natural Resources (DENR), through its Land Management Bureau (LMB), entered into a Consultancy Agreement with United Planners Consultants, Inc. (UPCI) to prepare the Land Resource Management Master Plan Project.
The total contract price was set at ₱4,337,141.00, with payments tied to predetermined percentages for each stage of work.

UPCI completed the required services in December 1994, formally accepted by DENR on December 27, 1994.
DENR paid only 47% of the contract price (₱2,038,456.30), leaving the balance unpaid.

On October 25, 1994, the Commission on Audit’s Technical Services Office reported the contract price as 84.14% excessive.
Despite this finding, DENR, in a December 10, 1998 letter, acknowledged an outstanding liability of ₱2,239,479.60 and undertook to pay “as soon as possible.”

UPCI filed a complaint before the RTC of Quezon City for non-payment. By agreement and under the arbitration clause, the case was referred to a CIAC‐administered arbitral tribunal.
Parties adopted the CIAC Revised Rules Governing Construction Arbitration. DENR missed the deadline to submit its draft decision; the tribunal deemed this a waiver but accepted DENR’s submission on the day of award promulgation (May 7, 2010).
The Arbitral Award (May 7, 2010) ordered DENR to pay UPCI:

₱2,285,089.89 for unpaid progress billings plus 12% interest per annum from finality;
₱2,033,034.59 accrued interest;
₱500,000 exemplary damages;
₱150,000 attorney’s fees;
₱182,119.44 proportionate arbitration costs.

DENR’s motion for reconsideration before the tribunal was merely noted. DENR then filed motions in the RTC (May 19 and June 1, 2010) contesting denial of hearing and lack of copy of the award.

On March 30, 2011, the RTC confirmed the arbitral award under Rule 11.2(A) of the Special ADR Rules and awarded ₱50,000 costs. No motion for reconsideration was filed.
Execution was issued on September 12, 2011. DENR moved to quash the writ, claiming premature execution and denial of due process.
On July 9, 2012, the RTC denied the motion to quash, ruling that DENR’s motions were procedurally defective under the CIAC Rules and that the award was final and executory.

DENR filed a certiorari petition before the Court of Appeals (CA), docketed as CA-G.R. SP No. 126458.
On March 26, 2014, the CA dismissed the petition on two grounds:

The petition impermissibly assailed the merits of the arbitral award (Rule 19.7, Special ADR Rules).
The petition was filed beyond the 15-day reglementary period (Rule 19.28, Special ADR Rules).

Whether the Court of Appeals gravely abused its discretion in dismissing DENR’s certiorari petition under the Special ADR Rules.
Whether the Special ADR Rules govern not only confirmation but also execution of confirmed awards, precluding recourse to the regular Rules of Court.
Whether DENR was deprived of due process in the arbitral and confirmation proceedings.