Title
Philippine Sports Commission vs. Dear John Services, Inc.
Case
G.R. No. 183260
Decision Date
Jul 4, 2012
A legal dispute ensues over the Philippine Sports Commission's bidding process for janitorial and security services, revealing issues of transparency and regulatory non-compliance.
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Case Digest (G.R. No. 183260)

Facts:

  • The Philippine Sports Commission (PSC) is the petitioner, and Dear John Services, Inc. is the respondent.
  • In December 2001, PSC published an invitation to bid for janitorial and security services.
  • Dear John Services expressed interest and paid the bidding fee.
  • On March 8, 2002, PSC Chairman Eric Buhain canceled the pre-bidding conference for evaluation of bidding procedures.
  • The invitation to bid was re-advertised, with pre-bidding and bidding set for April 16 and April 26, 2002, respectively.
  • Dear John Services submitted a bid of P18,560,078.00; Consolidated Building Maintenance, Inc. (CBMI) submitted a higher bid of P27,419,097.00.
  • PSC awarded the contract to CBMI, claiming Dear John Services did not meet the 60% lower limit of the Approved Agency Estimate (AAE).
  • Dear John Services requested reconsideration, arguing the AAE should have been disclosed before bidding.
  • They filed a complaint for injunction in the Regional Trial Court (RTC) of Parañaque City, seeking a temporary restraining order (TRO) against PSC.
  • The RTC issued a TRO on May 14, 2002, which was later extended but ultimately dismissed the complaint on November 29, 2006.
  • Dear John Services appealed to the Court of Appeals (CA), which reversed the RTC's ruling on April 17, 2008, awarding nominal damages of P200,000 to Dear John Services and dismissing the complaint against PSC.
  • The petitioners filed a motion for reconsideration, denied on June 11, 2008, leading to the current petition for review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that Dear John Services did not fail to meet the 60% lower limit of the AAE due to irregularities in the bidding process.
  • The Court held that PSC lacked a valid basis to reject Dear John Services' bid, as the reservation clause in t...(Unlock)

Ratio:

  • The Supreme Court emphasized that public bidding must adhere to principles of transparency, competitiveness, and accountability to protect public interest and ensure fair competition.
  • The PSC's failure to disclose the AAE prior to bidding v...continue reading

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