G.R. No. 217151 - Spouses Ang vs. De Venecia

Petitioners Reynaldo Ang and Susan Cucio-Ang (spouses Ang) own a two-storey residential house and lot in Barangay Singkamas, Makati City.
Respondent Angel Margarito D. Caramat, Jr. (Angel) began construction of a five-storey commercial building on the adjacent lot in 2008.

In 2009, the spouses Ang noticed structural damage including cracks in the walls and misalignment of the gate and doors.
The foundation of their house was found exposed and moved due to deeper excavation required for Angel’s building.

Spouses Ang sought mediation through barangay officials; Angel agreed to repairs and preventive measures.
Repairs were minimal (garage door realignment and brace installation), which spouses Ang found unsatisfactory.
Subsequent mediation attempts failed as Angel and his contractor’s representative, Soto, denied responsibility, attributing damage to weak foundation of Ang’s house.
Spouses Ang escalated complaint to the City Engineer, who demanded compliance with the National Building Code; Angel and Soto did not comply.
Spouses Ang obtained certification to file an action from the barangay.

On June 15, 2009, spouses Ang filed Civil Case No. 09-510 against Angel, Soto, architects Vilvar and others, including owners of the lot and the City Engineer.
The Caramats filed a third-party complaint against Soto and MC Soto Construction.
Pre-trial and presentation of evidence proceeded until August 2014.

OCA Circular No. 111-2014 reiterated the directive to dismiss construction disputes pending before trial courts and refer to the Construction Industry Arbitration Commission (CIAC).
The trial court, initially unaware of CIAC’s jurisdiction scope, suspended proceedings and instructed parties to await orders.
On November 12, 2014, the court dismissed the case and referred it to the CIAC.
Spouses Ang filed a Motion to Retain Jurisdiction and to Proceed with Trial on November 17, 2014, and a Motion for Reconsideration on December 17, 2014.
On February 20, 2015, the trial court denied the motions, affirmed dismissal, and reaffirmed referral of the case to the CIAC.

Spouses Ang filed a Petition for Review on April 27, 2015, challenging the trial court’s orders.
Respondents argued spouses Ang lost the right to question dismissal due to failure to timely file a motion for reconsideration.
Spouses Ang contended formal dismissal was not made in open court during the November 12, 2014 hearing and that their motions were timely.
The court’s November 21, 2014 Order indicated it received spouses Ang’s Manifestation and intended to resolve the motion, supporting their assertion of continued jurisdiction at that time.

Whether the Construction Industry Arbitration Commission (CIAC) has jurisdiction over a suit for damages filed by a non-party homeowner whose property was damaged by a neighbor’s construction project.
Whether the Regional Trial Court (RTC) erred in dismissing the spouses Ang’s suit and referring the case to the CIAC.
Whether the spouses Ang’s motions to retain jurisdiction and for reconsideration were timely and valid.