Case Digest (Adm. Case No. 1117) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Uniwide Sales Realty and Resources Corporation v. Titan-Ikeda Construction and Development Corporation (G.R. No. 126619, December 20, 2006), Uniwide (petitioner) and Titan-Ikeda (respondent) executed three construction agreements in 1991–1993: (1) a written contract for a Warehouse Club and Administration Building in Libis, Quezon City (Project 1, P120,936,591.50), completed February 15, 1992; (2) an unwritten undertaking to add a floor and renovate a warehouse at EDSA Central Market, Mandaluyong City (Project 2, estimated P21,301,075.77), completed October 1992; and (3) a written contract to build a Sales Department Store in Kalookan City (Project 3, P118,000,000.00), completed June 1993. After Uniwide allegedly withheld progress billings, Titan filed Civil Case No. 98-0814 in the Pasay City RTC but agreed to suspend proceedings in favor of arbitration under E.O. No. 1008 (CIAC Case No. 13-94). Before the CIAC, Uniwide denied liability, counterclaimed for refunds of overpaym... Case Digest (Adm. Case No. 1117) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Origin and Procedural History
- Titan-Ikeda Construction and Development Corporation (Titan) filed Civil Case No. 98-0814 before RTC, Pasay City, Branch 119, for unpaid claims against Uniwide Sales Realty and Resources Corporation (Uniwide) arising from three construction projects.
- Uniwide moved to suspend proceedings in favor of arbitration; Titan agreed. The case was stayed pending arbitration under Executive Order No. 1008.
- Contracts and Projects
- Project 1 (Libis Warehouse Club & Admin Bldg.)
- Written contract dated May 1991 for ₱120,936,591.50, completion by 30 November 1991; actual completion on 15 February 1992 and turnover to Uniwide.
- Dispute over ₱5,823,481.75 claimed by Titan for “additional works” allegedly without written authorization.
- Project 2 (EDSA Central Market Additional Floor & Renovation)
- No written contract; parties proceeded on drawings, specs and cost estimate of ₱21,301,075.77 (inclusive of 20% mark-up). Titan admitted receipt of ₱15,000,000.00. Completed in late October 1992.
- Uniwide counterclaimed for alleged overpricing, defective work and sought refund.
- Project 3 (Kalookan Sales Department Store)
- Written contract dated May 1992 for ₱118,000,000.00, completion by 28 February 1993; actual turnover in June 1993.
- Dispute over unpaid balance of ₱5,158,364.63 and VAT liability.
- Arbitration and Subsequent Decisions
- CIAC Proceedings
- Arbitral Tribunal formed; Parties signed Terms of Reference (TOR). Ocular inspection, hearings, affidavits with cross-examination, memoranda.
- Decision dated 17 April 1995 absolved Uniwide on Project 1 claims; held Uniwide liable for unpaid balances on Projects 2 and 3 with 12% interest; allocated VAT liabilities. Motion for reconsideration denied on 6 July 1995.
- Court of Appeals (CA)
- Uniwide’s petition for review filed in CA, CA-G.R. SP No. 37957.
- CA Decision dated 21 February 1996 modified CIAC ruling: reduced interest to 6%, denied direct BIR liability of Uniwide for Project 3 VAT, and made denial of liquidated damages “without prejudice.” Reconsideration denied on 30 September 1996.
- Supreme Court
- Uniwide filed petition for review under Rule 45 (G.R. No. 126619), raising four issues: mistaken payment for Project 1, VAT liability on Project 1, entitlement to liquidated damages for Projects 1 and 3, and liability for defects in Project 2.
Issues:
- Whether Uniwide is entitled to reimbursement of ₱5,823,481.75 paid for unauthorized additional works on Project 1.
- Whether Uniwide is liable for the Value-Added Tax (VAT) on Project 1 in the absence of a contractual stipulation.
- Whether Uniwide may recover liquidated damages for delay in Projects 1 and 3.
- Whether Uniwide is liable for the ₱6,301,075.77 unpaid balance on Project 2 and whether Titan can be held liable for alleged defective construction.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)