Title
Local Superior of the Servants of Charity, Inc. vs. Jody King Construction and Development Corp.
Case
G.R. No. 141715
Decision Date
Oct 12, 2005
Religious corporation breached contract by demanding additional works beyond original scope, causing delays; courts upheld contractor's claims for payment and damages.

Case Summary (G.R. No. 141715)

Key Dates

  • September 12, 1992: Contract awarded to Jody King Construction for construction works.
  • October 14, 1992: The building contract was signed, specifying the scope of works.
  • May 28, 1993: A second contract was signed for finishing works, alongside the requirement for additional works performed by the respondent.
  • September 19, 1994: The respondent filed a complaint for breach of contract with the Regional Trial Court.

Applicable Law

The governing documents and relevant laws include the contracts between the parties and applicable principles of Philippine contract law. The decision is anchored on provisions likely following the 1987 Philippine Constitution, given that it is post-1990.

Background of Dispute

The conflict stemmed from a contract for the construction of a spiritual formation center, initially priced at P14,327,000.00. The petitioners repeatedly modified the project scope, causing complications in settlement and additional works that would come to dispute later. During the contract execution, they requisitioned for additional constructions beyond the original agreement. Ultimately, the dispute led to claims from the respondent for unpaid billings and performing additional requested work.

Trial Court Findings

In an initial ruling, the Regional Trial Court found in favor of the respondent, ordering the petitioners to pay varying amounts for distinct breaches. The trial court held that the petitioners were obligated to fulfill payment for both the original and additional works despite the contention that such works were outside the original contracts. The total amount awarded included not only the value of the works performed but also additional costs incurred due to the various changes requested by the petitioners.

Court of Appeals Ruling

The Court of Appeals upheld the trial court's decision but modified certain monetary awards, particularly the interest rates applied to the judgments. The appellate court found adequate evidence to affirm the trial court’s conclusions and noted that many claims made by the petitioners regarding the additional works were not sufficiently substantiated.

Issues on Appeal

The primary issues raised by the petitioners revolved around factual disputes, including claims of poor work performance and the legitimacy of additional charges in the respondent's billing. However, the Supreme Court flagged these matters as questions of fact that had already been resolved by the lower courts, emphasizing the doctrine that trial court findings are afforded great respect in appeal.

Legal Principles Established

The decision underscored the principle that factual findings by lower courts, especially when affirmed b

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