Case Digest (G.R. No. 199513)
Facts:
Teresa Gutierrez Yamauchi v. Romeo F. Suniga, G.R. No. 199513, April 18, 2018, Supreme Court Third Division, Martires, J., writing for the Court. Petitioner Teresa Gutierrez Yamauchi sued respondent Romeo F. Suniga for rescission with a prayer for damages after a renovation contract for her Laguna Bel-Air house was suspended and allegedly performed in a defective and incomplete manner.In September 2000 Yamauchi engaged Suniga to renovate her house pursuant to a Scope of Works and an itemized Bill of Materials estimating total costs at about P869,658.00 (including P20,000 for permits). Yamauchi paid P300,000 on October 9, 2000 and P100,000 on January 31, 2001. By January–March 2001 work had largely ceased because Suniga was constructing his own house and requested additional funds; Yamauchi complained the billing was bloated and the work incomplete. Confrontations ensued, Suniga pulled out the workers and materials, and Yamauchi (through counsel) demanded the return of P400,000 plus interest. Suniga countered that he had accomplished portions of the work and demanded P49,512.50 for additional partially accomplished works.
Yamauchi filed her complaint on December 13, 2002, alleging misrepresentation (that Suniga was a licensed architect), nonconformity with agreed works, failure to complete by agreed time, and that the house was rendered uninhabitable—seeking rescission, damages and attorney’s fees. Suniga denied liability, asserted accomplishment of 47.02% of the works (supported by a Billing Summary and testimony of the foreman), and counterclaimed for unpaid obligations.
The Regional Trial Court (RTC), Branch 24, Manila, on January 28, 2008 rendered judgment rescinding the contract under Article 1191 of the Civil Code and ordered Suniga to pay Yamauchi: P400,000 actual damages; P50,000 moral; P50,000 exemplary; P30,000 attorney’s fees; and costs. Suniga appealed.
The Court of Appeals (CA) in a decision dated April 12, 2011 (with a November 22, 2011 resolution denying reconsideration) affirmed rescission but modified the damages awards: it reduced actual damages to P60,580 (finding Suniga had accomplished about 47% of the work and identifying specific overcharges to be returned) and deleted awards for moral and exemplary damages, attorney’s fees and costs, concluding there was no proof of fraud or bad faith and that Article 2208 prerequisites for a...(Pro-only)
Issues:
- Under Rule 45, may the Court review the CA’s factual findings on damages in this case?
- Did the Court of Appeals err in reducing the award for actual (compensatory) damages to P60,580.00?
- Did the Court of Appeals err in deleting the awards for moral and exemplary damages, attorney’s fees, a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)