Case Digest (G.R. No. 222423)
Facts:
Metropolitan Manila Development Authority v. D.M. Consunji, Inc. and R-II Builders, Inc., G.R. No. 222423, February 20, 2019, Supreme Court Second Division, Carpio, J., writing for the Court. Petitioner Metropolitan Manila Development Authority (MMDA) sought review of the Court of Appeals' 10 July 2015 Decision and 12 January 2016 Resolution in CA‑G.R. CV No. 95506, which affirmed the Regional Trial Court (RTC) of Makati City, Branch 133, decision of 9 June 2010 and order of 30 August 2012 in Civil Case No. 07‑942 awarding respondents D.M. Consunji, Inc. (DMCI) and R‑II Builders, Inc. (R‑II Builders) P19,920,936.17 plus interest for expenses allegedly incurred under an interim waste‑management contract.In 2000–2001 MMDA, with the Metro Manila mayors, pursued an interim waste disposal project under a negotiated contract. The project had been opened to public bidding and awarded to respondents, who proposed ferrying garbage from a transfer station in Pier 18 Vitas, Manila to Semirara Island. A contract titled “Contract for the Development, Operation and Maintenance of Interim Integrated Waste Management Facility for Metropolitan Manila” was executed on 4 January 2001 and signed by then MMDA Chairman Jejomar C. Binay and representatives of respondents, among others. Respondents began preparatory work from 2 to 5 January 2001 allegedly under Binay’s instruction, but operations were halted by two Temporary Restraining Orders issued by the RTC in Antique. President Estrada subsequently resigned, and the contract was never approved by the President.
Respondents demanded reimbursement of P20,123,190.00 for expenditures incurred and, after negotiation failed, filed a complaint on 12 September 2007 for sum of money based on quantum meruit with damages before the RTC (Civil Case No. 07‑942). The MMDA, through the Office of the Solicitor General, answered that the contract required presidential approval under RA 7718 and contract stipulations, that MMDA was not bound to pay mobilization expenses, and that money claims against government agencies fall under the Commission on Audit (COA) procedures (Act No. 3083, Commonwealth Act No. 327, PD 1445).
The RTC granted respondents’ motion for judgment on the pleadings and, on 9 June 2010, ordered MMDA to pay P19,920,936.17 with 6% legal interest. MMDA appealed to the Court of Appeals; respondents filed a partial appeal as to costs which the RTC denied on 30 August 2012. The Court of Appeals affirmed the R...(Subscriber-Only)
Issues:
- Does the Commission on Audit (COA) have primary jurisdiction over respondents’ money claim against MMDA?
- Was judgment on the pleadings proper in this case?
- Are respondents entitled to recover their expenses on the basis of...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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