Title
Republic vs. Technological Advocates for Agro-Forest Programs Association, Inc.
Case
G.R. No. 165333
Decision Date
Feb 9, 2010
The Supreme Court favored TAFPA, Inc. in a dispute with the DENR over unpaid claims, citing the latter's failure to pursue proper remedies.
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Case Digest (G.R. No. 165333)

Facts:

  • The case involves the Republic of the Philippines (DENR) as the petitioner and Technological Advocates for Agro-Forest Programs Association, Inc. (TAFPA, Inc.) as the respondent.
  • On November 27, 1995, TAFPA entered into a contract with DENR, Regional Office No. IX, for community organizing, social investigation, and an information education campaign at the San Isidro Tinago Reforestation Sub-Project in Zamboanga del Norte.
  • TAFPA submitted Accomplishment Reports and Requests for Billing on July 8, 1998, and June 7, 1999.
  • The Composite Inspection Committee (CIC) recommended payment of P802,350.64 to TAFPA.
  • On September 8, 1999, RED Antonio M. Mendoza informed TAFPA of a penalty of P1,192,611.00 for delays, resulting in a net liability of P390,260.36 for TAFPA.
  • TAFPA sought reconsideration, leading to a legal interpretation by Atty. Orlando V. Kong, clarifying that the penalty was for failure to complete services, not for report submission.
  • The National Forestation Development Office (NFDO) upheld the penalty, prompting TAFPA to file a special civil action for Mandamus in the RTC of Zamboanga City.
  • The RTC ruled in favor of TAFPA on March 16, 2001, ordering DENR to pay the claimed amount but dismissing the claim for moral damages.
  • DENR's motion for reconsideration was denied, and the decision became final.
  • DENR later sought to annul the RTC's judgment in the Court of Appeals, which was denied on September 9, 2004.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the Court of Appeals' ruling that the RTC had jurisdiction over TAFPA's cause of action.
  • The Court upheld TAFPA's entitlement to the payment of its money claim against DENR.
  • The Court ruled that DENR did not have a valid claim of lack ...(Unlock)

Ratio:

  • The Supreme Court reasoned that the RTC had jurisdiction as the case involved specific performance, which falls under the original jurisdiction of Regional Trial Courts per Batas ...continue reading

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