Title
Industrial Power Sales, Inc. vs. Sinsuat
Case
G.R. No. L-29171
Decision Date
Apr 15, 1988
The Supreme Court nullifies Secretary Sinsuat's contract award to Delta Motor Corporation, confirms IPSI's compliance with specifications, and orders Delta to pay damages to IPSI.
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Case Digest (G.R. No. L-29171)

Facts:

  • The case involves Industrial Power Sales, Inc. (IPSI) as the petitioner-appellant and Hon. Duma Sinsuat, Secretary of General Services, and Delta Motor Corporation as respondents-appellees.
  • In April 1965, the Bureau of Supply Coordination issued two Invitations to Bid for eight line construction trucks.
  • The first invitation (April 6, 1965) limited bids to foreign-made products on a CIF basis.
  • The second invitation (April 29, 1965) amended the first to include locally manufactured trucks on an FOB basis, following IPSI's suggestions.
  • The Acting Undersecretary of Public Works & Communications indicated that locally manufactured utility truck bodies could be accepted if they met specifications.
  • Bidding occurred on May 11, 1965, with IPSI and Delta participating.
  • The Committee on Awards recommended awarding the contract to IPSI, confirmed by the Acting Director of Supply on June 10, 1965.
  • Delta protested, claiming IPSI's trucks were not factory-built as required.
  • The Acting Director ruled in favor of IPSI on June 23, 1965, affirming compliance with specifications.
  • On July 16, 1965, Undersecretary Lachica attempted to reverse the approval, stating the requisition called for special factory-built trucks.
  • The Acting Director reaffirmed the award to IPSI.
  • Delta filed a protest with Secretary Sinsuat, who ruled in favor of Delta, stating only Delta complied with the original specifications.
  • IPSI filed a petition for certiorari, prohibition, and mandamus in the Quezon City Court of First Instance, which was dismissed, leading to an appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court reversed the trial court's decision, nullifying Secretary Sinsuat's orders and awarding attorney's fees to IPSI.
  • The Court found that the Secretary acted ...(Unlock)

Ratio:

  • The Supreme Court emphasized the principle of exhaustion of administrative remedies but recognized exceptions for purely legal issues or patently illegal acts.
  • The amended invitation to bid was deemed v...continue reading

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