Case Digest (G.R. No. 159561-62)
Facts:
R.V. Santos Company, Inc. v. Belle Corporation, G.R. Nos. 159561-62, October 03, 2012, the Supreme Court First Division, Leonardo‑De Castro, J., writing for the Court. Belle Corporation (respondent) filed a Request for Adjudication with the Construction Industry Arbitration Commission (CIAC) on November 3, 1999, alleging that it had overpaid RV Santos Company, Inc. (petitioner, RVSCI) under a July 14, 1997 construction contract for an underground electrical network for the Tagaytay Woodlands Condominium Project. The contract set a maximum project cost of P22,000,000 and provided for a 50% downpayment (P11,000,000). RVSCI issued an official receipt for that downpayment and subsequently submitted Progress Billing No. 1 dated August 10, 1998 claiming substantial accomplishment and additional work orders. Belle later re‑evaluated and contested the billed amounts, commissioned an independent audit by R.A. Mojica and Partners, and thereafter demanded return of alleged overpayments.CIAC proceedings: At the CIAC preliminary conference the parties adopted Terms of Reference limiting issues for arbitration; the CIAC received affidavits and held hearings on March 24 and 28, 2000. In a July 28, 2000 Decision the CIAC found that progress billing approvals are provisional, gave weight to the third‑party audit, concluded Belle had overpaid RVSCI, and ordered RVSCI to refund P4,940,108.58 with interest; it denied Belle’s claim for liquidated damages and denied RVSCI’s counterclaims for unpaid billings and attorneys’ fees.
Court of Appeals: Both parties sought judicial review under Rule 43 of the Rules of Court and the cases were consolidated as CA‑G.R. SP Nos. 60217 and 60224. The Court of Appeals, in a March 7, 2003 Decision, affirmed the CIAC award; subsequent motions for reconsideration were denied in an August 20, 2003 Resolution.
Supreme Court: RVSCI filed a petition for review on certiorari under Rule 45, challenging (1) the admissibility and weight given to the R.A. Mojica audit; (2) the CIAC’s and CA’s ruling that Belle could withdraw its prior approval of progress billing under Articles VI(2)(c) and XIII(4) of the contract; and (3) denial of RVSCI’s claim for damages. B...(Pro-only)
Issues:
- Procedural: Does RVSCI’s Rule 45 petition improperly raise questions of fact that are barred from review because the CIAC’s factual findings are final and binding?
- Substantive: Was the third‑party audit by R.A. Mojica admissible and properly given weight?
- Substantive: Was Belle’s prior approval of RVSCI’s progress billing final and unwithdrawable?
- Substantive: Is Belle liable to RVSCI for damages or other relief giv...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)