Title
Swire Realty Development Corp. vs. Specialty Contracts General and Construction Services, Inc.
Case
G.R. No. 188027
Decision Date
Aug 9, 2017
Swire Realty sued Specserv for breach of contract over incomplete waterproofing works. SC ruled Specserv liable for damages, rejecting claims of additional work, and reduced penalties.
A

Case Summary (G.R. No. 188027)

Procedural History

Swire filed a Complaint for Sum of Money and Damages alleging breach of the waterproofing Agreement. The Regional Trial Court (Quezon City, Branch 224) rendered judgment in favor of Swire ordering respondents to pay Php 400,000.00 (actual damages for monies advanced without completion), Php 124,931.40 (costs paid to Esicor to finish Specserv’s unfinished works), and Php 100,000.00 attorney’s fees. The RTC denied respondents’ motion for reconsideration. The Court of Appeals reversed and awarded Specserv Php 157,702.06 plus legal interest, finding that additional works were performed and calculating balance due. The Court of Appeals denied reconsideration. Swire then filed a petition for review on certiorari under Rule 45 with the Supreme Court.

Issues Presented to the Supreme Court

  1. Whether the Supreme Court may review the Court of Appeals’ findings of fact in a Rule 45 petition; and 2) Whether the waterproofing of the swimming pool constituted “additional works” outside the scope of the Agreement, thus entitling respondents to extra compensation.

Standard of Review and Exceptions to Rule 45 Finality

The Court reiterated the general rule that Rule 45 limits review to questions of law but acknowledged established exceptions (Medina v. Asistio) that permit review of factual findings when, inter alia, conclusions are grounded on speculation, are manifestly mistaken, the judgment is based on misapprehension of facts, findings are conflicting, or a finding is premised on supposed absence of evidence contradicted by the record. The Court found several such exceptions applicable here, particularly where the CA’s factual conclusion that the pool waterproofing was an “additional work” conflicted with the RTC’s findings and rested on a misapprehension of the contractual scope.

Contractual Scope and Whether Pool Waterproofing Was Additional Work

The Agreement’s Article I expressly enumerated the covered areas and systems, listing “Swimming Pool 234.20 sq.m. — Xypex” among the covered areas and stating the agreed unit prices per square meter. The Court held that this plain contractual enumeration demonstrates that all works necessary to accomplish waterproofing for the swimming pool were included in the contract price. A site instruction noting “2nd waterproofing after lightweight concrete topping” did not, in itself, convert the works into additional works because the pool was already a listed covered area. If respondents believed that the work called for by the site instruction constituted an additive change, they should have invoked Article VII (Change Orders) and sought a written agreement on additive work pricing before performing such work. Thus the Court concluded the CA erred in treating the pool waterproofing as additional compensated work.

Facts Adopted and Respondents’ Performance

The Court adopted facts affirmed by both the RTC and the CA: respondents accomplished only 90% of the waterproofing works; respondents failed to redeploy workers despite demand and the expiry of the 100-day period; respondents’ excuse (that the sump pit was not free from debris) was unsubstantiated; and there was no basis for respondents’ claim of “short payments” because progress billings were accepted by them and adjustments reflected the actual extent of accomplished work. These facts established a contractual breach by respondents.

Computation of Refunds and Actual Damages

Because respondents completed only 90% of the contract, the Court agreed with the RTC’s method of computing allowable deductions from the contract price, accounting for the unfinished 10% (Php 200,000), the 10% retention (Php 200,000), and the 1% withholding tax (Php 20,000), yielding aggregate allowable deductions of Php 420,000.00. The RTC had awarded only Php 400,000.00; the Supreme Court modified the award and ordered respondents to pay Php 420,000.00 as actual damages to Swire.

Reimbursement for Completion by Third Party (Esicor)

Under Article 1167 of the New Civil Code (if one obliged fails to do something, the same shall be executed at his cost), the Court upheld the RTC’s award ordering respondents to reimburse Swire Php 124,931.40—the contract price Swire paid to Esicor to complete Specserv’s unfinished work. The Court affirmed this award and incorporated it into the final disposition.

Penalty / Liquidated Damages: Reduction and Rationale

The Agreement imposed a penalty of Php 10,000.00 per day of delay. The Court recognized respondents’ delay extended to the date Esicor finished the remaining work (a period of 365 days), which would nominally yield Php 3,650,000.00. Applying Articles 1229 and 2227 of the New Civil Code and established jurisprudence allowing equitable reduction when penalties are unconscionable or the principal obligation is partly complied with, the Court found the contractual penalty manifestly excessive in light of respondents’ partial performance (90%) and lack of bad faith. The Court therefore reduced the penalty to Php 200,000.00 as liquidated damages.

Attorney’s Fees

The RTC had awarded Php 100,000.00 as attorney’s fees. The Supreme Court deleted that award, applying the PNCC v. APAC standard requiring a clear factual, legal, and equitable basis for attorney’s fees under Article 2208 of the Civil Code. The RTC’s sparse justification (“constrained to litigate”) was insufficient; thus the award of attorney’s fees was removed.

Disposition

The

    ...continue reading

    Analyze Cases Smarter, Faster
    Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.