Case Digest (G.R. No. 147933-34)
Facts:
Public Estates Authority v. Elpidio S. Uy, doing business under the name and style Edison Development & Construction, and the Court of Appeals, G.R. Nos. 147933-34, March 31, 2003, First Division, Ynares‑Santiago, J., writing for the Court.Petitioner Public Estates Authority (PEA), a government entity tasked by the Bases Conversion Development Authority to develop the Heritage Park in Fort Bonifacio, entered into a Landscaping and Construction Agreement on November 20, 1996 with respondent Elpidio S. Uy, doing business as Edison Development & Construction, to perform landscaping works on the 105‑hectare park. The contract provided for completion within 450 days after a written notice to proceed, later extended to 693 days. Delays were attributed in part to PEA’s failure to deliver 45 hectares for landscaping because of the presence of squatters and a public cemetery.
Respondent Uy filed CIAC Case No. 02‑2000 with the Construction Industry Arbitration Commission (CIAC) claiming damages for delay, including costs for idle equipment (P19,604,132.06), idled manpower (P2,275,721.00), additional topsoil hauling, mobilized water trucks, and P6,050,165.05 for construction of a nursery shade, plus attorney’s fees and interest. On May 16, 2000 the CIAC rendered an award in Uy’s favor in the amounts and with the interest terms set out in its dispositive portion.
Both parties sought review in the Court of Appeals: PEA filed CA‑G.R. SP No. 59308 challenging the monetary awards, and Uy filed CA‑G.R. SP No. 59849 seeking higher awards and recovery of denied claims. The petitions were consolidated; on September 25, 2000 the Court of Appeals issued a Joint Decision dismissing both petitions and affirming the CIAC award in toto. Motions for reconsideration were denied. PEA also sought a TRO/preliminary injunction to stop CIAC Case No. 03‑2001 (filed by Uy) on grounds of duplicative claims; on April 25, 2001 the Court of Appeals issued a Joint Resolution denying reconsideration and permanently enjoining the CIAC from proceeding with CIAC Case No. 03‑2001.
PEA filed a petition for review in this Court attacking (among other points) the dismissal by the Court of Appeals for a purported procedural defect (verification/certification of non‑forum shopping signed by an Officer‑in‑Charge allegedly without board authorization), the Court of Appeals’ affirmance of the CIAC awards, denial of PEA’s counterclaims (including unrecouped balances and attorney’s fees),...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in dismissing PEA’s petition for review for failure to comply with verification and certification requirements because those documents were signed by PEA’s Officer‑in‑Charge without a board resolution authorizing him to represent the corporation?
- Did the Court of Appeals err in affirming the CIAC’s monetary awards to Uy and in denying PEA’s counterclaims and other relief (including claims for unrecouped balances, attorney’s fees, n...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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