Case Digest (G.R. No. 250296)
Facts:
Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH) v. A.D. Gonzales, Jr. Construction and Trading Company, Inc., G.R. No. 250296, February 12, 2024, Supreme Court Second Division, Kho, Jr., J., writing for the Court. Gonzales Construction sued the DPWH for collection of a sum of money with damages, claiming it performed two government contracts: (1) Rehabilitation of Gumain-Porac Division Channel (PHP 2,695,980.00) and (2) Abacan River Control Cut-Off Channel (PHP 8,174,294.32). Gonzales signed the contracts for his company and DPWH officials handled the internal processing; Gonzales alleged both projects were inspected, found in accordance with specifications, and completed, but DPWH paid only a partial amount (PHP 1,178,252.42), leaving an unpaid balance.Gonzales Construction filed its complaint in the Regional Trial Court (Branch 46, San Fernando City, Pampanga), presented witnesses including a COA auditor and DPWH engineers, and documentary proof of work accomplished. DPWH raised defenses: sovereign immunity (no consent to suit), lack of certification of availability of funds under Presidential Decree No. 1445 (PD 1445), alleged unsigned contracts by required officials, and failure to exhaust administrative remedies. DPWH did not present evidence at trial.
The RTC, in a Decision dated July 17, 2014, ruled for Gonzales Construction and ordered DPWH to pay PHP 5,364,086.35 (the unpaid portion of the Abacan Project), PHP 50,000.00 attorney’s fees, and costs of suit; it found a perfected contract or at least an implied consent to be sued, applied quantum meruit, and determined 90.61% of the Abacan work was accomplished (value PHP 7,332,292.45 minus prior partial payment). The RTC dismissed Gonzales’ claim for the Gumain Project for lack of proof.
DPWH’s motion for reconsideration was denied (Order dated April 1, 2015), and it appealed to the Court of Appeals (CA). The CA, in a Decision dated January 31, 2019 (and Resolution of November 5, 2019 denying reconsideration), affirmed the RTC’s award of PHP 5,364,086.35 but deleted attorney’s fees and costs and added interest at 6% per annum from finality of judgment. The CA limited its review to assigned errors and applied the quantum meruit doctrine (citing DPWH v. Quiwa and R.G. Cabrera Construction v. DPWH and COA), finding ample evidence of 90.61% accomplishment and noting DPWH presented no contrary proof.
DPWH filed a Petition for Review on Certiorari under Rule 45 seeking reversal on the grounds that COA has primary jurisdiction over money claims (PD 1445) and that evidence d...(Pro-only)
Issues:
- Did the trial court and the Court of Appeals have jurisdiction to resolve Gonzales Construction’s money claim given the primary jurisdiction of the Commission on Audit under PD 1445?
- Did the Court of Appeals correctly affirm the RTC’s award of PHP 5,364,086.35 based on quantum meruit because Gonzales Construction proved 90.61% comple...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)