Case Summary (G.R. No. 168184)
Applicable Law
The 1987 Philippine Constitution serves as the legal framework for this case, given that the decision date is post-1990. The principles of contract law and the standards guiding the computation of damages and equity are particularly relevant.
Summary of Motions for Reconsideration
Uy filed a Motion for Partial Reconsideration aimed at disputing the damages calculation for standby equipment and seeking additional compensation for unauthorized costs incurred during construction. PEA responded with its own Motion for Reconsideration, challenging the validity of Uy’s claims based on the principle of res judicata, arguing the finality of earlier decisions rendered by the courts regarding these monetary claims.
Petitioner’s Claims on Damages
Uy contended that the methodology utilized to compute the damages for standby equipment costs failed to account for the actual number of equipment deployed during project delays. He argued for recalculating these costs using a formula that considers the duration of the delay and the precise array of equipment that remained on standby, as stipulated in the activities undertaken.
Court’s Ruling on Standby Equipment Costs
The court partially agreed with Uy, acknowledging his argument regarding the necessity of using actual equipment numbers in calculating standby costs. However, the Court noted that not all equipment mobilized was operational and mandated the remand of the case back to the Construction Industry Arbitration Commission (CIAC) for accurate calculations based on the adjusted formula.
Ruling on Additional Claims
Regarding the claims for reimbursement of additional hauling distances and mobilization of water trucks, the court maintained that any such claims required prior written consent from PEA, which Uy did not acquire. Thus, the court found that Uy could not invoke the principle of unjust enrichment to recover such costs, as the absence of formal approval undermined his claims.
Injunction and Res Judicata Considerations
In addressing the injunction from CIAC Case No. 03-2001, the court reiterated that Uy’s claims were interconnected and therefore fell under the same cause of action as outlined in the Construction and Landscaping Agreement. It emphasized that matters of res judicata apply, asserting that differing claims could not be pursued simply due to their variance in composition or form unless the facts presented were distinct.
Final Resolution
The court conclud
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Case Overview
- This case involves a dispute between Elpidio S. Uy, operating as Edison Development & Construction (EDC), and the Public Estates Authority (PEA).
- The proceedings concern Uy’s motion for partial reconsideration and PEA’s motion for reconsideration regarding a previous decision dated June 8, 2009.
- The Supreme Court partially grants Uy’s motion and denies PEA's motion with finality, affirming the decision with modifications.
Background of the Case
- Uy filed a petition against PEA seeking damages related to equipment rentals, idle manpower, and costs incurred during the construction of a nursery shade net area.
- The Court of Appeals previously affirmed a joint decision and resolution regarding the claims of Uy against PEA.
Court's Initial Decision (June 8, 2009)
- The Court ordered PEA to pay Uy the following amounts:
- P55,680,492.38 for standby equipment rentals
- P2,275,721.00 for idle manpower costs
- P6,050,165.05 for the construction of the nursery shade net area
- An interest rate of 6% per annum was mandated from the filing of the complaint until the decision's finality, increasing to 12% per annum thereafter until full payment.
- PEA was also ordered to pay 10% of the total award as attorney’s fees to Uy.
Petitioner’s Arguments for Partial Reconsideration
- Computation of Damages for Standby Equipment Costs:
- Uy contends that the factor rate used for calculating standby equipment costs was inaccurate.
- He argues that the actual number of equipment deployed during the delay should be factored into th