Case Digest (G.R. No. 147349)
Facts:
Manila International Airport Authority v. ALA Industries Corporation, G.R. No. 147349, February 13, 2004, First Division, Panganiban, J., writing for the Court. Petitioner Manila International Airport Authority (MIAA) contracted with respondent ALA Industries Corporation for structural repair and waterproofing of NAIA's International Passenger Terminal and International Container Terminal; ALA was awarded the contract after reducing its bid and the parties executed the contract on June 28, 1993 with detailed payment and warranty provisions. Progress billings were to be paid periodically but not more than once a month within 30 calendar days from receipt; ALA performed the work and submitted progress billings, receiving partial payments while Progress Billing No. 6 remained unpaid.On June 30, 1994 MIAA unilaterally rescinded the contract for alleged failure to complete on time; ALA objected and, after court-directed arbitration (July 16, 1996), the parties executed a compromise agreement and jointly moved for judgment. On November 4, 1997 the trial court (RTC) approved the compromise providing that MIAA would pay ALA P5,946,294.31 within thirty (30) days from receipt of a copy of the order approving the compromise and that failure to pay within that period would entitle ALA to a writ of execution to enforce all claims pleaded in the complaint.
MIAA failed to pay within the 30-day period. ALA moved for execution to enforce the compromise and sought the full amount pleaded (P13,118,129.84). MIAA paid the approved compromise amount belatedly on February 2, 1998 and explained noncompliance by reference to government processing and the Christmas season; the RTC denied ALA’s motion for execution and denied reconsideration (February 16, 1998), accepting the explanation. ALA appealed to the Court of Appeals (CA), which reversed on February 28, 2001 in CA-G.R. CV No. 59518, ordering issuance of a writ ...(Pro-only)
Issues:
- Whether the slight delay by petitioner MIAA in complying with the judicially approved compromise agreement justified enforcement by respondent ALA.
- Whether the delay is excused as a fortuitous event (caso fortuito) because it occurred during the Christmas season and arose from government processing procedures.
- Whether respondent ALA is estopped from enforcing its full claim because it accepted pa...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)