Case Digest (G.R. No. 161720) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In University of the Philippines vs. Hon. Agustin S. Dizon, Stern Builders, Inc. and Servillano Dela Cruz (G.R. No. 171182, August 23, 2012), the University of the Philippines (UP), represented by then‐President Jose V. Abueva and other officials, contracted on August 30, 1990 with Stern Builders, Inc., chaired by Servillano Dela Cruz, for the construction and renovation of buildings at UPLB. Stern Builders submitted three progress billings but UP, citing a COA disallowance, paid only two; the third billing of ₱273,729.47 remained unpaid even after COA lifted its disallowance. In 1993 Stern Builders and Dela Cruz sued UP and its officials in RTC Quezon City (Civil Case No. Q-93-14971) to recover the unpaid billing and damages. On November 28, 2001, the RTC awarded ₱503,462.74 (third billing and related costs), ₱5,716,729.00 actual damages, ₱10,000,000.00 moral damages, ₱150,000.00 plus ₱1,500.00 per appearance as attorney’s fees, and costs. UP’s motion for reconsideration was de Case Digest (G.R. No. 161720) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Contract and Progress Billings
- On August 30, 1990, the University of the Philippines (UP), through its President, entered into a General Construction Agreement with Stern Builders, Inc., represented by Servillano Dela Cruz, for extension and renovation works at the UPLB campus.
- Stern Builders submitted three progress billings; UP paid the first two but refused the third (P273,729.47) due to a COA disallowance, which was later lifted yet remained unpaid.
- RTC Judgment and Initial Execution Attempts
- Stern Builders and Dela Cruz sued UP and its officials in RTC Quezon City (Civil Case No. Q-93-14971). On November 28, 2001, RTC rendered a decision awarding:
- P503,462.74 (third billing and related items)
- P5,716,729.00 (actual damages)
- P10,000,000.00 (moral damages)
- P150,000.00 plus P1,500.00 per appearance (attorney’s fees)
- Costs of suit
- UP’s motion for reconsideration was denied May 7, 2002. UP filed a notice of appeal on June 3, 2002; RTC found it belated and, on September 26, 2002, denied the appeal and granted execution. The writ issued October 4, 2002; UP’s motions to quash and for reconsideration were denied.
- Appellate Proceedings and Garnishment
- CA dismissed UP’s certiorari petition February 24, 2004, affirming finality of RTC decision. SC denied UP’s petition for review on certiorari June 23, 2004 (final November 12, 2004).
- Stern Builders filed successive motions for execution; RTC issued garnishment notices (June–July 2003) to UP’s depository banks (Land Bank, DBP). UP’s motions to quash were denied; RTC repeatedly ordered release of garnished funds (October 2003, March 2004, December 2004).
- UP secured a TRO from CA (January 19, 2005) enjoining release. RTC later amended orders (May 3, 2005; July 8, 2005), directing deposit of check (P16,370,191.74). CA dismissed UP’s petition September 16, 2005; UP elevated to SC (G.R. No. 171182).
- Conflicting RTC Orders and Bank Compliance
- RTC (Judge Dizon) denied withdrawal of deposit January 30, 2006, pending final SC resolution.
- Successor judge (Judge Yadao) on January 3, 2007 allowed immediate withdrawal; UP obtained SC TRO January 24, 2007, but DBP released funds January 17, 2007. RTC denied UP’s motion to redeposit April 10, 2007.
Issues:
- Whether UP’s trust funds—public moneys—are proper subjects of garnishment absent a specific appropriation by Congress.
- Whether the RTC had jurisdiction to enforce execution against UP funds without prior COA adjudication under P.D. 1445.
- Whether UP’s notice of appeal, filed June 3, 2002, was timely in light of due process and the fresh-period rule.
- Whether the RTC’s awards of P5,716,729.00 (actual damages), P10,000,000.00 (moral damages), and attorney’s fees lack the required express findings of fact and law and thus are void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)