Case Summary (G.R. No. 173181)
Procedural History
The initial complaint was filed by KCD against Hutama and Yang on December 10, 2001, seeking payment for outstanding obligations under a contract entailing a Notice to Proceed dated November 10, 2000. Following a series of procedural motions, the Trial Court eventually declared the defendants in default due to their failure to file a responsive pleading within the allowed timeframe. The Regional Trial Court (RTC) ruled in favor of KCD, and Hutama and Yang appealed the decision to the Court of Appeals (CA).
Findings of the Regional Trial Court
The RTC found that Hutama contracted KCD as a sub-contractor for a specific construction project and that KCD issued a final billing amounting to P3,009,954.05, which was later agreed upon by both parties as P2,967,164.71. Despite this agreement, Hutama did not settle the payment, which led to KCD filing the complaint. The RTC, after evaluating the evidence presented, ordered Hutama and Yang to pay the owed amount, inclusive of interest and attorney's fees.
Issues on Appeal
Hutama contested the CA's affirmation of the RTC decision primarily on three grounds: (1) the alleged abandonment of the project by KCD, (2) the denial of their right to present evidence, which they claimed violated their constitutional right to due process, and (3) the supposed non-compliance of KCD with verification and certification requirements as outlined in the Rules of Civil Procedure. Additionally, Hutama complained about the CA's handling of their motion for reconsideration.
Legal Standards and Analysis
The Supreme Court highlighted that a petition under Rule 45 primarily addresses questions of law rather than fact. The Court confirmed that the CA's affirmation of the RTC’s factual findings was binding, except in specific exceptional circumstances, none of which applied in this case as neither court found that KCD had abandoned the project.
Regarding the alleged violation of due process, the Court held that the RTC acted within its discretion when it declared Hutama in default after they missed the deadline for their responsive pleading. The Court noted that the absence of Hutama's counsel during the hearing on their motion to set aside the order of default was inexcusable and did not constitute sufficient grounds to reverse the default ruling.
Verification and Certification of Non-Forum Shopping
Hutama contended that the verification and certification of non-forum shopping executed by KCD was invalid due to the lack of proof of authority of KCD’s president to sign these documents. However, the Court referenced previous rulings establishing that the president can indeed sign such documents, provided they have knowledge of the facts asserted. The Court affirmed that KCD adhered to
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Case Overview
- The case involves a petition for review on certiorari filed by Hutama-RSEA/Supermax Phils., J.V. against KCD Builders Corporation.
- The petition contests the Decision dated October 14, 2005, and the Resolution dated June 19, 2006, of the Court of Appeals (CA) in CA-G.R. CV No. 78262.
Factual Background
- On December 10, 2001, KCD Builders Corporation filed a complaint for a sum of money against Hutama-RSEA/Supermax and Charles H.C. Yang in the Regional Trial Court (RTC) of Makati.
- The complaint arose from a contract established through a Notice to Proceed dated November 10, 2000, where Hutama acted as the principal contractor for a project at Philips Semiconductors in Calamba, Laguna, and KCD as the subcontractor.
- KCD submitted a final billing of P3,009,954.05 on September 20, 2001, which was agreed to be reduced to P2,967,164.71 after a joint evaluation.
- Despite the agreement and subsequent demand for payment, Hutama failed to pay the owed amount.
- Summons were served to Hutama and Yang on February 8, 2002.
Procedural History
- Hutama's counsel filed an Entry of Appearance and a Motion for Extension of Time to file a Responsive Pleading, which was granted until March 16, 2002.
- KCD filed a Motion to Declare Hutama and Yang in Default on April 11, 2002, due to their failure to respond by the deadline.
- Hutama filed a Motion to Dismiss, arguing Yang was not pe