Case Summary (G.R. No. 214864)
Case Background
The dispute arises from a cargo-handling contract awarded to NIASSI by PPA, which was intended to operate solely at the Nasipit Port in Agusan del Norte. The case follows a series of events after NIASSI was awarded the contract through a public bidding process. Initially, NIASSI was declared as the winning bidder, but the second-highest bidder, Concord Arrastre and Stevedoring Corporation (CASCOR), raised concerns regarding NIASSI's stockholders, who were alleged to be legislators prohibited from holding financial interests in government contracts. Despite these allegations, on December 21, 2000, PPA issued a Notice of Award to NIASSI, which was accepted by the latter on January 3, 2001, though a formal contract was never executed. Instead, NIASSI requested a Hold-Over Authority (HOA), which allowed provisional cargo handling operations.
Court Proceedings and Injunctions
Disputes arose due to poor service quality associated with NIASSI, leading PPA to take over operations on December 10, 2004. Subsequently, NIASSI filed a Petition for Mandamus with a prayer for a writ of Preliminary Mandatory Injunction to compel PPA to execute the contract formally and to regain control over cargo handling operations. The Regional Trial Court (RTC) initially granted an injunction in favor of NIASSI but later reversed this decision.
Court of Appeals Decision
NIASSI appealed the RTC's reversal to the Court of Appeals (CA), which found that a perfected contract existed between NIASSI and PPA, despite the absence of a signed document. The CA determined that the HOA and its extensions represented partial fulfillment of the contract. It concluded that NIASSI had a clear legal right to operate the cargo-handling services at the port, and thus reinstated the initial injunction, allowing NIASSI to resume operations.
Supreme Court Ruling
PPA subsequently filed a Petition for Review, arguing that the CA's decision rendered the Amended Petition moot and academic. The Supreme Court held that the 10-year cargo-handling contract had indeed been perfected, with the condition that NIASSI's operations during the HOA constituted partial fulfillment of that contract. The Court clarified that PPA's attempts to take over the operation were in violation of NIASSI's rights under the existing contract.
However, it ultimately ruled that the 10-year contract's term had expired by the time of the petition, given NIASSI's operational history combined with the events dictati
...continue readingCase Syllabus (G.R. No. 214864)
Background and Nature of the Case
- This case concerns a Petition for Review on Certiorari filed under Rule 45 of the Rules of Court against the Amended Decision dated September 15, 2014, from the Court of Appeals (CA).
- The CA's decision arose from an Amended Petition for Mandamus filed by respondent Nasipit Integrated Arrastre and Stevedoring Services, Inc. (NIASSI) against the petitioner Philippine Ports Authority (PPA).
- NIASSI sought to compel PPA to execute a formal cargo-handling contract awarded to it.
Facts of the Case
- PPA, established under Presidential Decree No. 505, manages all ports in the Philippines, while NIASSI is a licensed cargo handling corporation.
- In November 2000, PPA accepted bids for a 10-year contract to operate as the sole cargo handler at Nasipit Port.
- PPA’s Pre-qualification, Bids and Awards Committee (PBAC) awarded the contract to NIASSI, leading to a Notice of Award issued on December 21, 2000.
- A protest was lodged by the second highest bidder, CASCOR, alleging that NIASSI's stockholders were legislators with prohibited interests in government contracts.
- Despite this, NIASSI acknowledged the Notice of Award on January 3, 2001, but requested a Hold-Over Authority (HOA) due to the pending protest.
- The HOA was granted and extended multiple times, ultimately expiring in 2004 when PPA revoked it, citing service complaints against NIASSI.
Proceedings in the Regional Trial Court (RTC)
- On December 10, 2004, the scheduled takeover of cargo-handling services by PPA prompted NIASSI to file a Petition for Injunction, later amended to seek a writ of mandamus.
- The RTC initially issued a writ of preliminar