Case Summary (G.R. No. 248971)
Facts of the Case
Estomo was awarded the contract in 1997, and the construction commenced shortly thereafter. Throughout the project, Estomo conducted additional works and submitted several demand letters requesting payment for these additional costs, which culminated in a total claim of P261,963.82 by November 1997. The CSC acknowledged the completion of some extra works but demanded rectification of deficiencies, leading to ongoing disputes over payments.
Procedural History
Estomo filed a Complaint for Specific Performance, Sum of Money plus Damages against the CSC after he was not fully compensated for his work, despite acknowledging extra costs incurred in the course of construction. The CSC countered this claim and asserted that enough documentation had not been provided to substantiate Estomo’s claims for additional payment.
Ruling of the Regional Trial Court (RTC)
The RTC ruled in favor of Estomo, ordering CSC to pay P387,104.14, including legal interests and attorney's fees, citing that a substantial completion of work had been established. The court’s decision highlighted that CSC could not invoke immunity from suit to deny its obligations as it had already benefited from the work completed.
Appeal to the Court of Appeals (CA)
The CSC appealed the RTC’s decision. The CA found that the additional works claimed by Estomo were requests that had not been formally approved by the CSC, thus ruling that only the amount of P144,735.98 for extra works, as per CSC Resolution No. 97-1101, was valid. The CA stated that Estomo’s demand for greater compensation would result in unjust enrichment.
Issues for Resolution
The key issues include whether the case raises factual disputes inappropriate for a Rule 45 review, whether the deductions made by CSC from the contract sum were warranted, and whether Estomo had a legitimate entitlement to the claimed amounts for extra works.
Legal Analysis and Findings
- Questions of Fact: The Supreme Court confirmed that while it generally refrains from weighing evidence in a Rule 45 petition, the conflicting factual determinations by the RTC and CA warranted examination.
- Deductions Validity: The Court upheld the legality of deductions related to retention money, tax, and advance payments. It was established that these deductions were made according to the provisions prescribed by Presidential Decree No. 1594.
- Claims for Extra Work: The Court agreed with the CA that Estomo’s requests for additional works were preliminary suggestions and lacked formal approval, rendering his claim for P261,963.82 invalid.
- Retention Money: Estomo was entitled to release of retention money from the progress payments
Case Syllabus (G.R. No. 248971)
Overview of the Case
- This case involves a Petition for Review on Certiorari filed by Domingo F. Estomo against the Civil Service Commission (CSC), Regional Office No. X.
- The case originates from a decision made by the Court of Appeals (CA) which reversed a previous ruling by the Regional Trial Court (RTC) regarding the contract for construction works.
- The CA concluded that the obligation of the CSC to Estomo was extinguished.
Background of the Case
- On April 29, 1997, the CSC awarded a contract to Estomo for the construction of the third floor of the CSC-X building, valued at ₱1,475,789.07.
- A contract was executed on May 6, 1997, and construction work commenced on May 8, 1997, with a target completion date of October 5, 1997.
- Estomo submitted multiple letters to the CSC for extra works needed, totaling additional costs that he claimed throughout the course of the project.
Progress of Construction and Payments
- Payments for construction were made in installments, with significant amounts paid on July 14, August 15, and September 26, 1997.
- Estomo requested additional payments for extra works, which he claimed amounted to ₱206,008.66 initially, later increasing to ₱261,963.82.
- Estomo sent demand letters and various documents to the CSC to support his claims for the extra works.
Dispute and Legal Proceedings
- The CSC admitted that some extra works were necessary but contested the compl