Title
Ultra Mar Aqua Resource, Inc. vs. Fermida Construction Services
Case
G.R. No. 191353
Decision Date
Apr 17, 2017
Construction dispute: Fermida completed warehouse for Ultra Mar, sought payment for contract and variations. Ultra Mar refused, citing defects. RTC ruled for Fermida; CA affirmed, SC upheld, removing 10% retention. Ultra Mar bound by counsel's negligence.

Case Summary (G.R. No. 223822)

Facts of the Case

On December 8, 2003, Fermida entered into a contract with Ultra Mar to construct a warehouse for a total price of PhP1,734,740. During the project, various modifications were made at Ultra Mar's request, including changes to the roof coverage and additional work. Following completion on January 17, 2004, Fermida issued a billing statement that excluded costs for these variations. Despite performing repairs upon request due to Ultra Mar's dissatisfaction with the work quality, Ultra Mar refused payment, claiming deficiencies and failure to provide necessary documentation. Subsequently, Fermida filed a complaint for collection against Ultra Mar.

Procedural History

The Regional Trial Court (RTC) ordered an ocular inspection of the construction site and scheduled a pre-trial conference, which encountered several postponements due to Ultra Mar's counsel's motions. Ultimately, Ultra Mar failed to appear or file a pre-trial brief, leading the RTC to declare it in default and allow Fermida to present evidence ex parte. Ultra Mar later attempted to lift the default order, citing its counsel's health issues as the reason for non-compliance. The RTC denied these motions, asserting that such failures warranted Fermida's advance with the case.

RTC Decision

On October 7, 2004, the RTC ruled in favor of Fermida, ordering Ultra Mar to pay PhP1,106,000.38, along with interest and other fees. Ultra Mar's attempts for reconsideration were rejected, leading to an appeal to the Court of Appeals (CA). The CA found no error in the RTC's handling of the case and upheld the decision, ruling that Fermida had satisfactorily established its claims.

Court of Appeals Findings

The CA's evaluation reaffirmed Fermida's assertion that the construction agreement was fulfilled despite Ultra Mar's contention of defective work. The independent engineer's reports highlighted completion issues but also addressed that the 10% retention from contract payments was mitigated by a Surety Bond secured by Fermida. The CA modified the RTC order, affirming Fermida's entitlement to payment while allowing Ultra Mar to retain the 10% retention amount pending any defects correction.

Issues on Appeal

Ultra Mar’s petition to the Supreme Court focused on alleged reversible errors by the CA regarding the default order and arguing that its counsel's negligence should excuse its non-compliance with pre-trial obligations. The petitioner maintained that it had a valid case and meritorious defenses that were not considered due to its default status.

Ruling of the Court

The Supreme Court ultimately ruled against Ultra Mar, affirming th

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