G.R. No. 222423 - Metropolitan Manila Development Authority vs. D.M. Consunji, Inc.

The MMDA, in coordination with the Greater Metro Manila Solid Waste Management Committee, initiated a selection process for the development and operation of a new sanitary landfill under the Build-Operate-Own (BOO) scheme, intended to replace the San Mateo landfill which had been closed on December 31, 2000.
The execution of this project faced hindrances when legal actions by groups in the affected area restrained MMDA from proceeding with the new landfill project.

In light of the stalled project, MMDA and the Metro Manila mayors agreed upon using an interim controlled dump site and selecting a contractor for a two-year period.
To implement this interim project, MMDA’s then Chairman, Jejomar C. Binay, endorsed the proposal to the Presidential Committee on Flagship Programs and Projects, which subsequently recommended it favorable to the Office of the President.
The project, opened for public bidding, was awarded to joint bidders—respondents D.M. Consunji, Inc. (DMCI) and R-II Builders, Inc.—and a contract for the development, operation, and maintenance of the interim integrated waste management facility was executed on January 4, 2001.

Despite the absence of the requisite approval and signature from then-President Joseph E. Estrada (as stipulated in the contract’s conditions), then MMDA Chairman Binay allegedly instructed the respondents to commence work, leading to the preparation of a transfer station in Pier 18 Vitas, Tondo, Manila, and the designated landfill site in Barangay Semirara, Semirara Island, Caluya, Antique.
Respondents performed work from January 2 to 5, 2001 under the supervision of the MMDA’s Office of the Assistant General Manager for Operations.
The project’s operations were subsequently halted when two temporary restraining orders (TROs) were issued by the Regional Trial Court (RTC), Antique, pending a hearing on an injunction.
Following President Estrada’s resignation, respondents sought reimbursement of expenses incurred—initially quantified at P20,123,190.00—asserting that the expenses were reasonably based on the work carried out under the contract.

MMDA’s legal service, particularly through the opinion of Atty. Vincent S. Tagoc, suggested that respondents might be compensated under the principle of quantum meruit, provided that the benefit to the government was duly considered; however, discrepancies were noted regarding evidence of any real benefit derived by MMDA.
Although Director Leopoldo V. Parumog of the MMDA’s Solid Waste Management Office recommended reimbursement, MMDA Chairman Bayani F. Fernando rejected the request on several grounds:

MMDA was not contractually obliged to pay for mobilization expenses.
A contractual stipulation (No. 13) provided that failure to perform due to mass or court actions would not give rise to claims by either party.
Another stipulation (No. 16) required the contract to have the expressed approval of the President—a condition unmet, rendering the contract invalid and ineffective.

Respondents filed a complaint on September 12, 2007, in Civil Case No. 07-942, seeking reimbursement (quantum meruit) along with damages, attorney’s fees, and litigation expenses.
The MMDA, represented by the Office of the Solicitor General, filed an answer emphasizing that the contract was void without the necessary presidential approval and citing statutory requirements (including those under RA 7718, Act No. 3083, and PD 1445) and the contractual provision barring claims due to mass or court actions.
Subsequent pleadings included a reply by respondents alleging bad faith on the part of MMDA by denying their claim and emphasizing internal memoranda supporting the reimbursement.
The trial court rendered a decision on June 9, 2010, awarding respondents P19,920,936.17 with 6% legal interest, a decision later appealed by MMDA.
The Court of Appeals (CA) affirmed the RTC’s decision, dismissing the appeals filed by both petitioner and respondents’ subsequent motions regarding litigation expenses.

Whether the trial court’s rendering of judgment on the pleadings was proper in resolving the dispute based solely on the admissions and documentary evidence presented without the need for further evidentiary hearings.

Whether respondents, having performed under an allegedly void contract but still rendering services from which MMDA derived benefit, are entitled to recover their expenses on the basis of quantum meruit even if the contractual formalities were not met.

Whether the COA holds primary jurisdiction over money claims against a government agency such as MMDA, thereby necessitating that respondents file their claim with the COA rather than pursuing it through the courts.