Case Summary (G.R. No. 102193-97)
Factual Antecedents
In January 1998, ACDC was awarded a contract for the development of the Philippine Centennial Exposition, which included the construction of several food establishments at a designated site in Clarkfield, Pampanga. Subsequently, ACDC contracted Tulabut to supply necessary labor, materials, and supervision for the project, with an agreement stipulating a payment of P3,414,058.60 via progress billing. By June 8, 1998, ACDC had only a minor balance of P3,246.12 remaining after making most payments. In July 1998, ACDC engaged Tulabut for additional construction work valued at P400,000.75. ACDC issued a check to Tulabut as partial payment; however, the check was later dishonored due to insufficient funds. Despite completing the project, Tulabut was not compensated in full, leading him to file a complaint for collection with the Regional Trial Court (RTC) of San Fernando, Pampanga.
Legal Proceedings and Trial Court Decision
Tulabut's complaint stated that by May 29, 1998, ACDC owed him P900,000.00—exclusive of damages and attorney's fees—and requested a writ of preliminary attachment. The RTC granted the attachment after Tulabut posted a bond. ACDC’s response contested the completeness of the work and claimed it had overpaid based on actual accomplishments. Tulabut presented evidence during the proceedings, including acknowledgment of receiving a partial payment of P125,571.81. The trial court eventually ruled in favor of Tulabut, ordering ACDC to pay the outstanding balance of P364,083.76, legal interest, and attorney's fees.
Court of Appeals Ruling
ACDC's appeal to the Court of Appeals (CA) contested the ruling by arguing that any liability for payment should be triggered only after a certificate of completion was issued. The CA dismissed the appeal and modified the lower court's decision, based on the principle of estoppel, asserting that ACDC had approved the relevant purchase orders and billings. The CA decreased the award for attorney’s fees to 10% of the amount due. The appellate court maintained that ACDC failed to substantiate its claim that it was standard practice in the construction industry for retention payments to occur only upon the issuance of a completion certificate.
Arguments by the Petitioner
In seeking relief from the SC, ACDC argued that the CA erroneously applied estoppel, assuming project completion without sufficient evidence. It insisted that the approval of documents like purchase orders did not equate to acknowledging the completion of work. Additionally, ACDC contended that the CA improperly awarded attorney's fees, asserting it had acted in good faith despite the dishonored check.
Supreme Court’s Rationale and Findings
The Supreme Court determined that the crux of the appeal hinged on factual issues rather than legal ones, emphasizing that only
...continue readingCase Syllabus (G.R. No. 102193-97)
Case Citation
- 496 Phil. 777
- G.R. No. 161904, April 26, 2005
Parties Involved
- Petitioner: Asian Construction and Development Corporation (ACDC)
- Respondent: Noel T. Tulabut, doing business as N.T. Tulabut Construction Supply
Procedural History
- This case is a petition for review on certiorari under Rule 45 of the Revised Rules of Court.
- The petition seeks the reversal of the Decision of the Court of Appeals (CA) in CA-G.R. CV No. 73124, which affirmed, with modifications, the Decision of the Regional Trial Court (RTC) of San Fernando, Pampanga, in Civil Case No. 11820.
Factual Antecedents
- In January 1998, ACDC was awarded a contract for the development of the Philippine Centennial Exposition at Clarkfield, Pampanga.
- In February 1998, ACDC contracted with Noel T. Tulabut for labor, materials, tools, equipment, and supervision to construct various food service facilities at the project site.
- The agreed contract price was P3,414,058.60, payable through progress billing.
- By June 8, 1998, ACDC had paid all but a small balance of P3,246.12.
- ACDC later contracted additional work for two more cafeterias via Purchase Order No. 73-985, with a net cost of P400,000.75.
- ACDC issued a check for partial payment (Land Bank Check No. 0000074516), which was dishonored due to insufficient funds.
- The total amount due as of the final billing dated November 26, 1998, was P486,409.45.
- Despite demands for payment from the respondent, ACDC failed to settle the outstanding balance, prompting the respondent to file a complaint for collection in RTC San Fernando.
Trial Court Proceedings
- The complai