Case Summary (G.R. No. 200759)
Factual Background
On June 15, 1999, the petitioner and respondent entered into a construction agreement for the construction of a residential building located in San Lorenzo Village, Makati City, with a total contract price of ₱12,500,000. Payment was to be made on a progress billing basis after inspection of work completed. By the time respondent had paid a total of ₱10,592,194.80, she refused to pay an additional ₱851,601.58 claimed in two progress billing statements dated October 31 and November 6, 2000. Following further disputes over additional work and payment refusals, and pursuant to Article 27(b) of the Uniform General Conditions of Contract for Private Construction, the petitioner terminated the contract. Respondent subsequently filed a complaint against the petitioner for defects and delays in the construction.
Proceedings at the Trial Court
The respondent's counterclaim against the petitioner included allegations of defective work resulting in significant damages, totaling over ₱3 million in actual damages, with additional claims for lost rentals and moral damages. The trial commenced but was marked by delays primarily due to the petitioner's failure to present evidence and witnesses, leading the trial court to dismiss the case for failure to prosecute. The dismissal prompted the petitioner to file several motions for reconsideration, all of which were ultimately denied.
Ruling of the Regional Trial Court
In a decision rendered on January 30, 2006, the trial court ruled in favor of the respondent, finding overwhelming evidence of the petitioner's defective workmanship and delay in construction. The court ordered the petitioner to pay various amounts, including actual damages, lost rentals, moral and exemplary damages, penalties for delay, and attorney's fees.
Appeal to the Court of Appeals
The petitioner appealed the trial court's decision, claiming that the dismissal of its own complaint was unjust due to the negligence of its counsel. The Court of Appeals upheld the trial court's ruling, emphasized that the negligence of a client's counsel binds the client, and confirmed that res judicata barred any further claims regarding the dismissal of the petitioner's case.
Arguments Before the Supreme Court
The petitioner's arguments in the Supreme Court included claims of error regarding the application of res judicata, the factual basis for the damages awarded, and criticisms of the evidence presented against them. The petitioner contended that the respondent had not sufficiently proved her damages and that penalties for delay were excessive. In contrast, the respondent maintained that the appellate court had appropriately ruled on the established facts and that the petitioner’s claims were moot.
Supreme Court Ruling
The Supreme Court denied the petition, reinforcing that the court does not re-evaluate factual findings established by lower courts. It upheld the Court of Appeals’ determination that the petitioner had failed to fulfill its obligations under the contract due to abandonment and defective work. The
...continue readingCase Syllabus (G.R. No. 200759)
Introduction
- The Supreme Court reiterates the principle that it is not a trier of facts and typically does not re-examine evidence from trial.
- This case arises from a Petition for Review on Certiorari by FAJ Construction & Development Corporation (petitioner) against Susan M. Saulog (respondent) aiming to overturn the Court of Appeals' decisions affirming the trial court's ruling.
Factual Antecedents
- On June 15, 1999, a construction agreement was made between petitioner and respondent for a residential building in Makati City, with a total contract price of P12,500,000.00.
- Petitioner received a total payment of P10,592,194.80 but respondent refused to pay an additional P851,601.58, leading to termination of the contract by the petitioner based on the Uniform General Conditions of Contract.
- Respondent countered with claims of defective work and damages, leading to a civil case filed by the petitioner for collection.
Procedural History
- The trial court (RTC) initially allowed the case to proceed, but after multiple delays and failure of the petitioner to present evidence, the case was dismissed for failure to prosecute.
- Petitioner’s motions for reconsideration were denied, prompting an appeal to the Court of Appeals, which upheld the trial court's dismissal and found the petitioner engaged in dilatory tactics.
Ruling of the Regional Trial Court
- The trial court ruled in favor of the respondent on her counterclaim, concluding that:
- Petitioner’s work was defecti