Case Summary (G.R. No. 187552-53)
Antecedents of the Dispute
The controversy originated from a contract for the execution of builder's work for Phases I and II and the Car Parking Structure of the EDSA Plaza Project, which was executed between SLPI and BFC. BFC filed a lawsuit against SLPI for the collection of P228,630,807.80, which was subsequently submitted for arbitration at CIAC. The case highlights the key issues, primarily concerning various claims for damages, unpaid work, and the procedural matters related to arbitration.
The Arbitral Tribunal's Findings
The Arbitral Tribunal composed of Engr. Eliseo Evangelista, Ms. Alicia Tiongson, and Atty. Mario Eugenio Lim carefully reviewed the claims of both parties. The Tribunal ruled in favor of BFC for several claims related to unpaid progress billings, changes to work orders, and retention money, while granting SLPI its counterclaim for liquidated damages due to delays. The final net award indicated that SLPI owed BFC P38,518,494.73, plus legal interest.
Court of Appeals Ruling
The Court of Appeals (CA) partially granted the consolidated petitions from SLPI and BFC, affirming certain aspects of the Arbitral Tribunal's decision while modifying financial awards. This included increasing BFC’s award for unpaid progress billings based on original scope work while reducing other claims. The CA decisions highlighted procedural considerations of the arbitration context and the evidence presented.
Issues from the Appeal
Both parties raised several issues during the appeal process:
- BFC challenged the CA’s denial of its claims for variation works and damages caused by SLPI’s nominated sub-contractors.
- SLPI contended against the increased awards granted to BFC from the Arbitral Tribunal’s original amounts, particularly for unpaid progress billings and liquidated damages.
Judicial Review of Factual Findings
The Supreme Court reviewed the appeal, noting its limitations regarding factual findings as a general principle while also recognizing exceptions wherein factual discrepancies and contradictions can allow for judicial intervention. The Court reaffirmed the principle that factual determinations made by specialized tribunals like CIAC are to be respected unless clear and convincing evidence of error is presented.
Conclusion on Variation Works
The Court upheld the Arbitral Tribunal's findings on BFC's claims for variation works authorized by SLPI, reinforcing the need for written instructions as per Article 1724 of the Civil Code. This decision underscored the necessity for proper documentation in variation claims and the recognition of terms agreed upon in the contractual relationship.
Rulings on Damages and Interest
With regard to BFC's claims for damages caused by sub-contractors and for fire damage and repairs, the Court agreed with the lower courts’ findings that BFC was not entitled to those claims due to a lack of proof demonstrating SLPI's liability or the existence of recoverable insurance proceeds. BFC’s challenges regarding the computation of legal interest were also addressed, with the Court restoring the amounts stipulated by the Arbitral Tribunal.
Final Jud
...continue readingCase Syllabus (G.R. No. 187552-53)
Overview of the Case
- The case involves the consolidated appeals of Shangri-La Properties, Inc. (SLPI) and BF Corporation (BFC) concerning a construction agreement dispute related to the EDSA Plaza Project in Mandaluyong City.
- The appeals were made to challenge the decisions of the Court of Appeals (CA) which modified the award of the Arbitral Tribunal that originally ruled on the case involving claims for damages and unpaid billings.
Factual Background
- A construction agreement was entered between SLPI as the project owner and BFC as the trade contractor for the execution of various phases of the EDSA Plaza Project.
- BFC filed a lawsuit against SLPI and its board members for the collection of Php 228,630,807.80, resulting in Civil Case No. 63400 at the Regional Trial Court of Pasig City.
- The trial court proceedings were stayed pending arbitration as required by their contract.
- An arbitration request by BFC was filed with the Construction Industry Arbitration Commission (CIAC), which was dismissed without prejudice, necessitating that arbitration proceed in accordance with Republic Act No. 876.
- The Arbitral Tribunal, comprising of Engr. Eliseo Evangelista, Ms. Alicia Tiongson, and Atty. Mario Eugenio Lim, was appointed to resolve various issues concerning the dispute.
Issues Submitted for Resolution
- The Arbitral Tribunal was tasked with determining several issues, including:
- BFC's entitlement to claims for damages and unpaid progress billings.
- The validity of claims regarding fire damage and repairs.
- Counte