G.R. No. 147925-26 - Uy vs. Public Estates Authority

Petitioner Elpidio S. Uy, doing business under the name and style Edison Development and Construction (EDC), entered into a Landscaping and Construction Agreement with the Public Estates Authority (PEA) for the development of a 105-hectare demilitarized lot in Fort Bonifacio, Taguig City into a first-class memorial park designated as Heritage Park.
The contract, priced at P355,080,141.15, required EDC to complete the landscaping works within 450 days upon receipt of the notice to proceed.

Although EDC received the notice to proceed on December 3, 1996, and began mobilization on December 6, 1996, the actual landscaping work did not start until January 7, 1997 due to non-delivery of work areas by PEA caused by ongoing horizontal works by Makati Development Corporation (MDC).
Continuous delays in the turnover of work areas led to an extension of the contract period from 450 days to 693 days.
A subsequent Change Order (No. 2-LC) on March 15, 1999 excluded a 45-square-meter portion of the park occupied by squatters, further modifying the scope of work.

EDC claimed additional costs amounting to P181,338,056.30 due to idle equipment rental, idle manpower, extra topsoil hauling expenses caused by depletion at the original supply source, and the need to mobilize water trucks and construct a nursery shade.
The PEA Project Management Office (PEA-PMO) evaluated these claims and arrived at a lower amount of P146,484,910.
The dispute led to EDC filing a complaint with the Construction Industry Arbitration Commission (CIAC) under CIAC Case No. 02-2000, where the CIAC granted awards for:

Dissatisfied with the CIAC’s computed award and its lesser amount compared to his original claim, Uy filed a motion for correction of computation, and, upon non-resolution within the prescribed period, elevated his case with a petition for review to the Court of Appeals (CA).
The CA, addressing both Uy’s petition and PEA’s separate petition in consolidated cases CA-G.R. SP Nos. 59308 and 59849, dismissed both on technical and substantive grounds while affirming the CIAC’s award in substance.
PEA subsequently sought an injunction to stop further proceedings in a related CIAC case (CIAC Case No. 03-2001), alleging that the claims were based on the same contractual controversy.

PEA’s memorandum of January 6, 2000, evaluated EDC’s various claims but did not expressly admit liability; it merely verified the accuracy of EDC’s submissions subject to review and change orders.
Throughout the proceedings, both parties argued on points of computation, the appropriateness of the changes and additional costs, and whether proper written approvals for extra work were secured as required by the contract provisions and governing law.

Whether EDC’s (Uy’s) petition for review was timely filed, considering the interruption of the appeal period by his motion for correction of computation and the subsequent CIAC order denying that motion.

Whether the Court of Appeals erred in affirming the CIAC decision that awarded a reduced amount for standby equipment costs and in modifying EDC’s claimed additional costs based on delays and scope reduction.
Whether PEA’s memorandum should be interpreted as an admission of liability for the higher evaluated amount.

Whether Uy is entitled to recover additional costs for topsoil hauling from a farther source and the mobilization of water trucks despite not having secured the required prior written approval as mandated by the contract and Article 1724 of the Civil Code.

Whether the reduction of the stipulated attorney’s fees from 20% to 10% of the total award was proper and justified under the contract terms and applicable legal standards.

Whether the Court of Appeals acted without or in excess of its jurisdiction—amounting to grave abuse of discretion—by enjoining the proceedings in CIAC Case No. 03-2001, particularly since that case allegedly involved claims different from the instant case.