Title
Supreme Court
Uniwide Sales Realty and Resources Corp. vs. Titan-Ikeda Construction and Development Corporation
Case
G.R. No. 126619
Decision Date
Dec 20, 2006
Construction disputes between Titan and Uniwide over three projects: overpayments, VAT liability, delays, and defects. CIAC ruled for Titan; SC affirmed with modifications, denying Uniwide's claims.

Case Digest (Adm. Case No. 1117)
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)

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