Title
Arenas vs. Court of Appeals
Case
G.R. No. 56524
Decision Date
Jan 27, 1989
Architect Cruz prepared plans, supervised construction, and claimed P100,000 fees; Arenas disputed, alleging a P30,000 fixed fee. Court ruled Cruz entitled to full payment, rejecting fixed fee claim, but denied moral damages and attorney’s fees.

Case Summary (G.R. No. 56524)

Factual Background

In January 1970, the petitioners engaged the services of the respondent to prepare architectural plans and to supervise the construction of their house for a fee based on the National Code of Architects Services and Fees in the Philippines. Initially, the agreed fee was 10% of the project costs for regular services, plus an additional 10% for project administration services. The respondent prepared several sets of plans, secured necessary approvals, and supervised construction, which began in March 1971 and was completed in June 1971. The petitioners paid the respondent an initial fee of P10,000.00 but declined to pay the remaining balance of P90,000.00 after the construction was completed, leading to the legal dispute.

Claims and Counterclaims

The respondent’s claim emphasized that his professional fees were based on the final building cost of over P500,000.00, while the petitioners contended that the initial agreement limited compensation to P30,000.00. The petitioners asserted that the respondent provided inadequate services, resulting in delays, and further claimed to have hired other architects for additional work on the house. They also pointed out shortcomings in the plans submitted by the respondent.

Court Decisions

The trial court ordered the petitioners to pay the respondent P90,000.00 in unpaid fees, with interest, along with P20,000.00 for moral damages and P10,000.00 as attorney's fees. Upon appeal, the Court of Appeals modified the decision by removing the moral damage award. The appellate court affirmed the trial court's findings, which were largely based on the evidence that demonstrated the respondent's substantial contribution to the architectural services.

Analysis of Evidence

The appellate court placed significant weight on the factual results of the evidence presented. Multiple sets of plans and specifications prepared by the respondent were established, with no contradictory evidence produced by the petitioners to contest the respondent's claims. Testimonies from the petitioners themselves corroborated the respondent's assertions regarding the professional services rendered. The failure of the petitioners to present alternative plans interpreted as a failure on their part to substantiate their claims of inadequacy against the respondent.

Compensation for Services

The Court established that the petitioners owed the respondent based on the professional fees permitted by the National Code of Architects Services and Fees. Given the actual construction costs confirmed during the proceedings, it was concluded that the proper calculation of the respondent's fees exceeded what had already been paid. The petitioners' use of lower estimates for fee calculations was deemed inadequate due to s

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