Case Summary (A.M. No. P-90-429)
The Facts of the Case
The MMDA initiated a selection process to develop a new sanitary landfill, led by inquiries and legal actions that stalled project progression. Despite legal impediments, MMDA under Chairman Jejomar Binay sought to implement an interim solution by securing approval from the Office of the President for an interim waste disposal site. The contract was eventually awarded to DMCI and R-II Builders for the construction of a facility on Semirara Island. Following the contract's signing, operations commenced under supervision; however, they were abruptly halted by subsequent temporary restraining orders (TROs) issued by a Regional Trial Court. In light of these events, the respondents sought reimbursement for incurred costs, leading to disputes regarding liability due to contractual requirements and restrictions.
Procedural Background
Respondents filed a complaint against MMDA for reimbursement based on the principle of quantum meruit, asserting a right to compensation for their expenditures. The MMDA countered that the contract was invalid due to the lack of presidential approval and claimed state immunity from suit. The trial court found in favor of the respondents, awarding them the claimed expenses and imposing a legal interest. Subsequent appeals by MMDA were dismissed by the Court of Appeals, upholding the trial court's decision and dismissing MMDA’s arguments regarding contract validity and state immunity.
Court of Appeals Ruling
The Court of Appeals affirmed the trial court's judgment, stating that the matter was suitable for judgment on the pleadings given the clarity of admissions within the documentary evidence. The court found DMCI and R-II Builders entitled to reimbursement, applying the quantum meruit doctrine, emphasizing that the MMDA had received benefits from the respondents' actions despite asserting contract invalidity. The court also rejected MMDA's defense of state immunity, framing it as inadequate justification to evade obligations to private entities.
Issues on Appeal
MMDA raised questions regarding the propriety of judgment on the pleadings, the entitlement of the respondents to reimbursement based on quantum meruit, and the jurisdiction of the Commission on Audit (COA) over the present claims.
Court's Analysis on Jurisdiction
The ruling first addressed jurisdiction, highlighting that the claim against the MMDA was a specific money claim which fell under the COA's primary jurisdiction, estab
...continue readingCase Syllabus (A.M. No. P-90-429)
The Case
- This petition challenges the 10 July 2015 Decision and the 12 January 2016 Resolution of the Court of Appeals in CA-G.R. CV No. 95506.
- The Court of Appeals dismissed the appeals of the Metropolitan Manila Development Authority (MMDA) and the respondents, affirming the 9 June 2010 Decision and 30 August 2012 Order of the Regional Trial Court of Makati City, Branch 133 in Civil Case No. 07-942.
- MMDA's motion for reconsideration was denied.
The Facts
- MMDA, in collaboration with the Greater Metro Manila Solid Waste Management Committee, initiated a selection process for the development and operation of a new sanitary landfill under the Build-Operate-Own (BOO) scheme, aimed at replacing the closed San Mateo landfill.
- Legal actions by concerned societal sectors hindered the progress of the landfill project, leading MMDA to choose an interim waste disposal site.
- Approved by President Joseph E. Estrada, the project was awarded to respondents D.M. Consunji, Inc. (DMCI) and R-II Builders, who proposed an integrated solid waste management facility on Semirara Island, Caluya, Antique.
- A contract titled "Contract for the Development, Operation and Maintenance of Interim Integrated Waste Management Facility for Metropolitan Manila" was signed on 4 January 2001.
- Respondents commenced preparations for the project under MMDA's instructions before the contract received final presidential approval.
- Two temporary restraining orders (TROs) from the Regional Trial Co